Background checks again.

[Adios]

I had to sort through all that chafe to get to the wheat.



The rest is quite simple - indeed, no need for angst. Each state will be examining how they wish to proceed with their new responsibilities.



.

Absolutely. State licensing agencies and their background checks have nothing to do with the responsibility of lenders and their third parties. Different purposes, different regulators, different regulations.

This seems to be a constant source of confusion.

 

[Evincere]

Joan, Thank you.

Thank you for providing sound reasoning's why appraisers should be background checking those who own 10% or more of every AMC they might work for. You're saying the state can't be trusted to do this, even though the federal law requires it. Appraisers risk much more, personally, on a bad AMC than any bank risks on an appraiser. While the $ number may be higher on the bank's side, as a percent of income, it's far greater on the appraiser's end, and therefore is a greater risk to appraisers, than banks.

You're quickly running out of appraisers to advantage, tell your clients to expect the tide to turn in a big way. After all, they want appraisers to state compliance with Frank/Dodd, great! Pony up for a background check of the owners of the AMC, as required by the law.


.

And to wrap it up nice and neatly regarding Appraisers;

Originally Posted by Joan Trice View Post

I had a nice conversation with the OCC last week on this topic.

There never will be a reg that states that background checks must be run, what type and so on.

No confusion whatsoever. Lenders requiring a bc is a business decision done at their own discretion.

 

[Adios]

There you go, "assuming" again.

So for just this one time, I will humor you with the same -

With the new laws coming into effect in 2017, and the states now just being granted the power of oversight and responsibility we have yet to know after they organize, whether they will change their policy and come to some sort of reciprocity and allow the bc's to be made available to the Appraiser...for sharing with Lenders and other states.

As far as states screening, I have no doubt they will have to consider the new agency guidelines regarding what constitutes a crime serious enough to preclude licensing vs arbitrarily deciding using their own standards.

It took time, but DL information was eventually nationalized. If a persons license was suspended or revoked in another state for whatever reason, every state now has that information.

What the states will or will not do, remains to be seen. You are just trying to beat them to the bank. Stop sounding so desperate.

You seem confused between AQB and Dodd Frank.

Banks are not regulated by State appraisal agencies.

FBI background checks cannot be shared. So if sharing were to happen the AQB would need to change their policy.

Again nothing to do with bank regulation.

 

[PropertyEconomics]

You seem confused between AQB and Dodd Frank.

Banks are not regulated by State appraisal agencies.

FBI background checks cannot be shared. So if sharing were to happen the AQB would need to change their policy.

Again nothing to do with bank regulation.

So if FBI background checks cannot be shared, why do you share background checks with your "potential clients" even if they are redacted? It seems to me there is a protocol for NOT sharing .. which you have simply ignored to achieve your own ends.

That is kind of dishonest, disgusting, and sad all at the same time. And yet you pretend to be in the business with the appraisers interest in mind.

 

[Adios]

So if FBI background checks cannot be shared, why do you share background checks with your "potential clients" even if they are redacted? It seems to me there is a protocol for NOT sharing .. which you have simply ignored to achieve your own ends.

That is kind of dishonest, disgusting, and sad all at the same time. And yet you pretend to be in the business with the appraisers interest in mind.

Odd that you all bait me to divulge backgrounds yet when I redact them you skewer me. I have never divulged anyone's private information. It is no different than you redacting an appraisal.

We do share XFILES. They are publicly accessible.

 

[Adios]

So if FBI background checks cannot be shared, why do you share background checks with your "potential clients" even if they are redacted? It seems to me there is a protocol for NOT sharing .. which you have simply ignored to achieve your own ends.

That is kind of dishonest, disgusting, and sad all at the same time. And yet you pretend to be in the business with the appraisers interest in mind.

I have honest, competent appraisers' interests in mind. Not so much the ones who are criminals. They do everyone harm.

 

[Eli]

I have honest, competent appraisers' interests in mind. Not so much the ones who are criminals. They do everyone harm.

I have a new idea.

You have the appraiser's best interest in mind and the lender's best interest in mind.

So, what about marketing to the general public, particularly upper lower and middle income home buyers and try to uncover both the criminal lenders and the criminal appraisers. If you landed one of the top criminals first, it might only take one to really boost your business. But I think you would have to start at the top of the food chain.

 

[PropertyEconomics]

I have honest, competent appraisers' interests in mind. Not so much the ones who are criminals. They do everyone harm.

You missed the point .. and you darn well know what it is.

IF YOUR CLIENT chose not to have background checks that is their business .. you should not hand select the worst from your little voyeuristic foray for them to see as you sell your wares like a carnival barker.

Im sorry but its dishonest and opportunistic. Please dont tell everyone its the honest appraisers you are protecting ... the bottom line your bottom line. Nothing more.

 

[PropertyEconomics]

Odd that you all bait me to divulge backgrounds yet when I redact them you skewer me. I have never divulged anyone's private information. It is no different than you redacting an appraisal.

We do share XFILES. They are publicly accessible.

There is a tremendous difference ... a redacted appraisal is provided WITH THE PERMISSION of the client... did you ask the appraisers if you could redact their background checks and provide them?

 

[Eli]

On second thought, you could still market to your existing subscribers that you could uncover their criminal lenders, you know the Bonnie and Clyde descendents that are employees trying to beat the system. Just think of the loan losses you could save them and might catch a bad appraiser or two along the way while finding the unethical lenders breaking the rules. What do you think?