Deadline Approaching: Federal Reserve System Seek Public Comment

[ramrcdk]

HERE IS THE LINK. BE SURE TO READ
AND FOLLOW THE PROPER INSTRUCTIONS OF "HOW TO POST"

SAD TO SAY: THE CURRENT NUMBER IS UNDER 300.

Yesterday I finally received a mass mailing notification from our local NCREA
Seems a bit late with just a few days to go.

https://www.regulations.gov/document?D=OCC_FRDOC_0001-0233


Addresses
Interested parties are encouraged to submit written comments jointly to all of the agencies. Commenters should use the title “Real Estate Appraisals” to facilitate the organization and distribution of comments among the agencies. Interested parties are invited to submit written comments to:

Office of the Comptroller of the Currency: You may submit comments to the OCC by any of the methods set forth below. Commenters are encouraged to submit comments through the Federal eRulemaking Portal or email, if possible. Please use the title “Real Estate Appraisals” to facilitate the organization and distribution of the comments. You may submit comments by any of the following methods:

• Federal eRulemaking Portal—“Regulations.gov”: Go to www.regulations.gov. Enter “Docket ID OCC-2018-0038” in the Search Box and click “Search.” Click on “Comment Now” to submit public comments.
• Click on the “Help” tab on the Regulations.gov home page to get information on using Regulations.gov,including instructions for submitting public comments.
• Email: regs.comments@occ.treas.gov.
• Mail: Legislative and Regulatory Activities Division, Office of the Comptroller of the Currency, 400 7th Street SW, Suite 3E-218, Washington, DC 20219.
• Hand Delivery/Courier: 400 7th Street SW, Suite 3E-218, Washington, DC 20219.
• Fax: (571) 465-4326.

Instructions: You must include “OCC” as the agency name and “Docket ID OCC-2018-0038” in your comment.

 

[djd09]

What can one say?
Cost and Time savings? Check, Cheap and Fast.
Safe and Sound? Check, Cheap and Fast.
Bailouts? Check
Evaluations over Appraisals? Unsafe and Unsound.
Soon.

 

[chad hampton]

I'm also in NC, I've received quite a few email notices from them. I believe they also published a letter on behalf of their members they sent it.

Maybe I've seen more or get more because I'm a member?

 

[Restrain]

Doesn’t matter what we say,mothering mind is made up thanks to all the money.

 

[Amy Perkins]

The proposed rule to increase the threshold level from $250,000 to $400,000 for an appraisal requirement would be to the public detriment. Appraisals ensure that loans are rated and underwritten to a certain degree that ensures public trust. These loans are rated and sold as mortgage backed securities, which again are sold to the public. Insurance (PMI) on these loans is also at risk should these requirements change. If manipulative practices are engaged for these evaluations such as they were in the past with AVMs (Automated Valuation modules) loan fraud will increase. There is no replacement for an appraiser's knowledge and experience. Appraisers know which properties are risky in declining or increasing markets. Those factors will not be reflected in an evaluation or psuedo-appraisal, nor does it have the backing of a credible appraiser. Four hundred thousand dollars is a large amount of money and combined over large land masses could extend huge risk and volatility to the overall market. There is no lack of appraisers, if anything there are too many appraisers. After the patriot act made borrowers provide tax income verification for the anti-money laundering act about 30% of the borrowers were disqualified. The appraisers who supported this volume of work are still in the workforce. There is an overabundance of appraisers. This change will put thousands of skilled workers out of business. Evaluations are completed by real estate agents who are not able to provide a reliable independent opinion; their role is to provide loyalty to their client. Agents are advocates and should never be treated as independent determinants of value. This is inconsistent, unsafe, and unsound banking practices. The proposed rule is not in conformance with the Uniform Standards of Professional Appraisal Practice for which all appraisers adhere. The proposed rule puts both the banking and insurance industries at great risk as well as consumer protection. Those properties on busy streets, near commercial, those next door to boarded up condos, those with high voltage power lines will be overvalued; primarily because they have not been properly appraised by an independent unbiased appraiser.

 

[Bob Ipock]

The proposed rule to increase the threshold level from $250,000 to $400,000 for an appraisal requirement would be to the public detriment. Appraisals ensure that loans are rated and underwritten to a certain degree that ensures public trust. These loans are rated and sold as mortgage backed securities, which again are sold to the public. Insurance (PMI) on these loans is also at risk should these requirements change. If manipulative practices are engaged for these evaluations such as they were in the past with AVMs (Automated Valuation modules) loan fraud will increase. There is no replacement for an appraiser's knowledge and experience. Appraisers know which properties are risky in declining or increasing markets. Those factors will not be reflected in an evaluation or psuedo-appraisal, nor does it have the backing of a credible appraiser. Four hundred thousand dollars is a large amount of money and combined over large land masses could extend huge risk and volatility to the overall market. There is no lack of appraisers, if anything there are too many appraisers. After the patriot act made borrowers provide tax income verification for the anti-money laundering act about 30% of the borrowers were disqualified. The appraisers who supported this volume of work are still in the workforce. There is an overabundance of appraisers. This change will put thousands of skilled workers out of business. Evaluations are completed by real estate agents who are not able to provide a reliable independent opinion; their role is to provide loyalty to their client. Agents are advocates and should never be treated as independent determinants of value. This is inconsistent, unsafe, and unsound banking practices. The proposed rule is not in conformance with the Uniform Standards of Professional Appraisal Practice for which all appraisers adhere. The proposed rule puts both the banking and insurance industries at great risk as well as consumer protection. Those properties on busy streets, near commercial, those next door to boarded up condos, those with high voltage power lines will be overvalued; primarily because they have not been properly appraised by an independent unbiased appraiser.