Monthly Archives: July 2015
Herb Meyer, ARA – ICAP Director reports on the Collinsville ICAP Seminar held on June 12th at the Doubletree Hotel.
Ted Neff (ICAP Director) opened the day with a brief welcome and an introduction of Thomas Kneesel, SRA.
Chief Appraiser for Associated Bank
Collateral Underwriter from a Reviewers Perspective – Fannie Mae Approved Presentation
- CU as just one of several appraisal review tools
- Since implementation at Associated Bank, the number of appraisal resubmits for has now returned to 30%, same rate as pre-Collateral Underwriting
- The 15 and 25 percent net and gross adjustment rules have been officially removed
- Underwriters no longer consider fewer and smaller adjustments as a better appraisal
- A surprising amount of disparity between appraisers found in appraisal reports for square footage and room adjustments. Also in ratings such as quality of construction and condition. For example, different appraiser condition ratings for the same sale can range from C2 to C4.
- OCC is auditing banks to determine if the AMC’s are paying customary and reasonable fees. Tom indicated that it is the OCC’s duty (and other regulators) to complete these audits under Dodd Frank.
- Fannie Mae indicated that the reasons for appraisers being placed in a watch list have to do with some non-appraisal issues. One example was an appraiser that signs 200+/- appraisals per month and indicates in every appraisal that they physically inspected all of the properties that cover a 200 mile radius from the office.
Keith Wolf, SRA, AI-RRS.
Statistics: Gambling with your License
- Several AMV’s and other statistic providers were discussed
- Computer based statistical programs could support better and worse adjustments. The appraiser has to be responsibility to understanding how the programs work and how to make the adjustments meaningful.
- Focused around Standard 6 being Mass Appraisal and also Advisory Opinion 6 on Comparable Sales. Discussed confounding data and confidence ratings.
- Wolf indicated that the banks are charged with determining customary and reasonable fees by the Dodd Frank Law. He spoke briefly about the AMC that was recently charged with not paying customary and reasonable fees in Louisiana.
IL Program Director, USDA
Overview of USDA for Residential Appraisers
- FmHA’s need for appraisers to prepare appraisals for their loan programs including direct loans and loan guarantees for rural residential properties and houses in towns of low population.
- Covered topics regarding requirements in appraisals for the different types of loan products available from the Rural Development division of the USDA.
- Discussed the required components of the home inspection that the appraiser must complete and the requirements for licensed home inspectors.
- The water well inspections and when a borrower is required to connect to available public water and sewer. The water and septic inspections are dependent upon available procedures in each community.
- Mr. Ramsey is seeking appraisers for some highly specialized appraisals on subsidized multi-family residential projects. These properties have interest rate subsidies, extreme long loan amortizations and rental rate controls. They are typically senior housing and other low rent restricted properties where the rent is a percent of the occupant’s income.
Realtor and Owner of Your Home Team Real Estate
IAR Update on Southern Illinois Market Conditions
- Discussed the local housing market and the relationship between Realtors and Appraisers.
- Encouraged appraisers to talk with realtors and know what they can talk about
- Questions the appraiser can expect and don’t take it personal
ICAP’s Compliance Issues on Residential Appraisals
- Discussed Appraiser Compliance
- Appraisers should clean up templates and have multiple templates for various assignment types
- Reminded appraisers of requirement to report the appraisal fee in the report and explained how it helps banks and lenders understand the AMC fee structure
Applications are currently being taken for positions on its 2016 Board of Directors. Becoming an ICAP Director is a unique opportunity to work with some of the leaders of the appraisal profession in Illinois as they influence legislation, regulation and public opinion toward the appraisal profession. Applications need to be in no later than August 1, 2015. Click here to see ICAP Service Opportunities.
IMPORTANT MESSAGE: CALL TO ACTION
This must be done by Tuesday July 7th.
The Consumer Financial Protection Bureau (CFPB) is requesting comments on the proposed amendment to the “Know Before You Owe” mortgage disclosure rule, which proposes to move the rule’s effective date to October 3, 2015.
As noted in our last ICAP Blog, your ICAP Board of Directors feel it is very important that the appraisal fee be disclosed separately from any add on fees such as an AMC fee.
Recently 23 state appraiser coalitions, including ICAP, worked together and submitted a letter to the CFPB about making it a requirement to separate the fees of the AMC and the appraiser at the closing table on the disclosures.
Now it is our turn to do our part and I am asking that you take a minute to make a personal comment to the CFPB. This is a part of appraisers having a seat at the table in our industry.
Right now there are 79 comments and almost every one of them are from Banks and AMC’s.
Appraisers also need to express our opinion on this issue.
Keep it simple it’s about transparency for the consumer, but there is a sample comment below feel free to use it or create your own. It’s just important that you make a comment.
- Click on the comment icon above or below to submit your comments.
- Read the Proposed Rule by CFPB
- To comment click on “Comment Now!” at the upper right corner of the webpage
- Add your comment. See Sample Comment Below.
Let’s flood them with comments from appraisers.
Once you have done this please forward this to another appraiser.
This is a sample comment……Feel free to copy and paste, edit or submit something totally different but please make a comment.
“Appraisal” fees to consumers continue to rise while the actual payments to appraisers have fallen. As with any business, a focus of third party appraisal management companies is to increase their profits. Under the current disclosures, there is no benefit or accountability to the consumer since the AMC fees are not listed independently.
The result of this lumping together of the fee often misleads the consumer to think that the appraiser fee is high. Currently, (with no separation requirement), a consumer might see an “appraisal” fee for $600 or more, with no awareness that the appraiser they met at their home and has completed their report is only being paid as little as $300 or less.
We ask that the Bureau recognize this major concern and take this proposed delay, in an attempt to “get it right”, as an opportunity to address this issue. I implore that you implement this simple solution of requiring the actual appraisal fee to be disclosed on its own, not an inflated fee that includes other administrative bank or AMC “add-ons”.
ICAP works to promote the appraisal profession and its image to the general public and to users of appraisal services. ICAP initiates discussion and analysis of issues affecting professional appraisers and monitors political action with the intent to influence legislation, regulation and public opinion toward the appraisal profession.
ICAP’s Board of Directors have agreed to participate and be one of potentially 21 state organizations signing a letter to the Consumer Financial Protection Bureau (CFPB). The letter was drafted by the Network of State Appraiser Organizations (NSAO)and is in response to the CFPB request for comments on the proposed amendment to the “Know Before You Owe” mortgage disclosure rule, which proposes to move the rule’s effective date to October 3, 2015.
The letter specifically addresses the lack of requirement to mandate disclosure to the consumer that the fee paid for an “appraisal” be clearly defined and break down what portion is being paid to the lenders’ third party appraisal management company and which portion of the fee is actually paid to the appraiser. Click here read the Letter.