How Appraisal Regulation Failed

[Terrel L. Shields]

could cause "information overload"

Like one more tidbit would break your brain after wading thru dozens of pages of piffle and having a bored loan officer condensed it into one sentence to try and speed the process along... laughable indeed. The AMC does not want the appraiser to know how big a bite they are taking from the apple.

 

[Sadie]

The term they used to suppress the disclosure of fee splits was "information overload." As if a simple one-line sentence would cause the poor consumer's fragile brain to fry? .

AI Overview


The
CFPB (Consumer Financial Protection Bureau) currently permits, but does not require, the separation of appraisal fees from Appraisal Management Company (AMC) fees on closing disclosures, citing concerns that mandated, granular breakdowns could cause "information overload" for consumers. While industry groups argue this bundled, or opaque, approach masks true costs, hampers competition, and reduces appraisal quality, the CFPB has traditionally resisted mandatory separation to keep disclosures simple.

The borrower's poor little brains!. They might explode if they have too much information.

 

[Mile High Trout]

In terms of the appraisal industry timeline, the article was written yesterday, will continue to be a valid critiquie for years to come.

If these are our small business advocates, who needs enemies?

Don't lie and misdirect and call for specific examples when they are everywhere to be seen. There are numerous conflicts of interests with so many people in these groups, members and management alike. When one researches both large and small AMC's, here comes the people in charge of policy, running the show and keeping the competition out. Is there even a small business supporter among them anymore?

What kind of incompetency level is needed to allow your own industry to shed a third of licensees whom are not replaced and do nothing about it?

https://appraisersblogs.com/bias-accusation-collapses-as-HUD-clears-the-appraiser/#comment-46348

We could start with the management rule that one shall not accept a thing of value to be the preferred selectee of the assignment. That thing of value of course being an appraisal fee discount for volume assignments. The discount becomes a bribe for the AMC, incentivizing them to select that appraiser more. The appraiser receives the gift back with the lions share of assignments. This promotes outsourcing, corner cutting, use of runners and unlicensed inspectors, drives quality down. These are out in the open industry problems that nobody tackles. We have an entire country of individual people, making individual loan decisions, working with individual loans and individual agents. Then only one in ten of the available appraisers is even allowed to tap into the workload.

Or one could dare to tackle older rules such as fair billing among clients that you should not price gouge opportunistically. Apply that same logic to an appraiser whom enjoys three times their normal AMC fee, when getting VA orders. Is the AMC being under charged, or the VA client being over charged? Which is it?

This industry is an embarrassment with far reaching economic implications for every day Americans. Ethical principals left the building so very long ago. Only the rare few still hold on for belief in consumer protection principals. It's happening at scale right now, the fruits of decades of incompetent management and co opted insider appeasement. This housing bubble is insanely large. When institutional investors 'stakeholder interests' drive the modeling that results in a fifth of all residential housing, no longer being owned by individual citizens. The system is designed to exploit people. The appraisal trade groups are derelict in their duty to represent the licensed appraisers, as well as abhorrently dismissive of the merits of sound consumer protection in appraisal assignment modeling. They represent nobody but themselves.

Fire everyone. Clear the bench.

https://www.workingre.com/wp-content/uploads/2013/08/IVPI-Proposalfinal.pdf

It's never to late to stop lying and support honest fair process instead.

 

[Mile High Trout]

The borrower's poor little brains!. They might explode if they have too much information.

The name of the game is capturing market share. You can't claim an unfair advantage in a transparent system with open and honest disclosure.

Restriction of trade. Rackateering. Junk fee billing violations.

These people deserve to be in prison.

https://www.findlaw.com/smallbusiness/business-laws-and-regulations/restraint-of-trade.html

Sherman Antitrust Act - Wikipedia

en.wikipedia.org

What kind of 'competent' organization takes over a decade to write a two page letter after forty thousand small business appraiser licensees are driven out, with no follow up?

https://www.appraisers.org/docs/default-source/advocacy/appraisal-orgs-to-cfpb-on-mortgage-fee-rfi.pdf?sfvrsn=256bd440_1

Biggers used to cover this monthly with far more competency. The appraisal trade groups are worthless.

 

[glenn walker]

It never failed it was just written before technology had changed how appraisals would be developed and delivered. It was just made obsolete and someone needs to abolish and get rid of most of the rules.

 

[George Hatch]

You guys already know in advance how the attys are going to argue both the "discount" as well as the "kickback" allegations, right? If not, you can probably figure it out for yourselves by putting a few minutes of roleplay into it.

 

[glenn walker]

Another big nothing burger.

 

[Tom D]

Another big nothing burger.

HEY!!!
I want my bite of that nothing burger, getting to thin. Lucky, but unfortunate, that i starded at the end of the golden age of appraising, then going into the ruling of satan AMC.

 

[Terrel L. Shields]

Summary

AI still thinks they own the appraisal profession.
CE has become nothing to do with improving the techniques, procedures or rules governing the appraisal profession. It's all about being non-racial, non-biased, and not offending anyone thus is non-effective as a result.
Forces outside the profession are dictating the rules.
Appraisers are regulated by Bankers, Realtors, and AMCs posing as good-faith intermediaries between the rule makers and the borrowers who actually pay for it all.
Anyone not in the bank-lending-management circle are non-persons, non-appraisers who have no say in the rule making. Frankly no appraiser should be regulated except for a Federally Related Transaction. NONE. There is no purpose in it. There is no reason for it. It serves no one.

The one and only appraiser I know who was convicted of a crime was not regulated by a board nor a society. He was charged in a real court by real law enforcement and convicted. This was before regulation.

 

[Carnivore]

In NC we had one appraiser who was convicted of Mortgage Fraud. It was big deal he knowingly got in with a fraud ring The big Guy got off rather light because he ratted out everyone he did have to pay restitution the attorney was disbarred The appraiser got 6 years
and and 3 million which he never paid. State Board visited him in prison and he surrendered his license.