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FDIC Breaking State Law?

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Maverick

Thread Starter
Sophomore Member
Joined
Feb 19, 2004
Professional Status
Certified Residential Appraiser
State
Oklahoma
Have you noticed that in this press release: http://www.FDIC.gov/consumers/loans/loanmod/index.html



... in regard to "FDIC Loss Sharing Proposal to Promote Affordable Loan Modifications"



... the word "appraisal" was never mentioned, but the following was stated:



Reduced Loss Share Percentage for "Underwater Loans": For LTVs above 100%, the government loss share will be progressively reduced from 50% to 20% as the current LTV rises.*1 If the LTV for the first lien exceeds 150%, no loss sharing would be provided.



*1 Current LTV can be demonstrated by a Broker Price opinion, or BPO [emphasis added].



So ... the FDIC is sanctioning the use of BPOs in lieu of appraisals when making loan modifications.



The Appraisal Institute, jointly with other appraisal organizations, sent this letter (see number 1 page one) on November 19th:



http://www.appraisalinstitute.org/n...ASA-NAIFA-ASFMRA_FDICLoanMods-11-19-Final.pdf
 

Carnivore

Elite Member
Supporting Member
Joined
Jan 15, 2002
Professional Status
Certified Residential Appraiser
State
North Carolina
Maverick,

They can do what they want be cause the have juice.

RE Agents on the other hand donot have enough juice in North Carolina and are not allowed by State General Statute to prepare BPO's for anything but a listing.

Now all I need to do is catch one and off to court we go!!!
 

Mike Boyd

Elite Member
Joined
Jan 18, 2002
Professional Status
Retired Appraiser
State
California
Finally, the AI has taken a position on behalf of licenced or certified appraisers. I commend their action.
 

Terrel L. Shields

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Joined
May 2, 2002
Professional Status
Certified General Appraiser
State
Arkansas
The AI can promote their organization better with such measures than anything else they do. Defending the appraiser instead of trying to work out deals with the bankers and brokers to provide a shortcut product is a win-win for AI and all appraisers. Promoting AVMs and working with AMCs is the lose-lose situation. I think they are beginning to catch on what appraisers MUST be independent and cooperation is not part of the job description because cooperation means compromise and compromise means capitulation.
 

Tom McClure

Sophomore Member
Joined
Jan 18, 2005
Professional Status
Certified Residential Appraiser
State
Ohio
The AI can promote their organization better with such measures than anything else they do. Defending the appraiser instead of trying to work out deals with the bankers and brokers to provide a shortcut product is a win-win for AI and all appraisers. Promoting AVMs and working with AMCs is the lose-lose situation. I think they are beginning to catch on what appraisers MUST be independent and cooperation is not part of the job description because cooperation means compromise and compromise means capitulation.

I agree, as a group NAIFA, ASFMRA, ASA & AI are on the right path. This was a group effort.
One large voice always has a better chance of being heard. Unification is clearly the answer for our profession. But this is probably the best we will ever do.

Tom McClure, Ohio
 

Walter Kirk

Senior Member
Joined
Jun 24, 2003
Professional Status
Licensed Appraiser
State
New Jersey
I will join and pay dues to any organization which begins a court action to force the FDIC, Freddie, Fannie, etc. to use only licensed or certified apptaisers as the law requires.

I would be happy to support any organization which works effectively to eliminate the Deminimus.

I will kiss the feet of the leader of any organization that works to require that AMC fees be disclosed and that AMC's must comply with USPAP.

Any takers?
 

Non Sequitur

Elite Member
Supporting Member
Joined
Feb 14, 2002
Professional Status
Certified Residential Appraiser
State
Louisiana
I will join and pay dues to any organization which begins a court action to force the FDIC, Freddie, Fannie, etc. to use only licensed or certified apptaisers as the law requires.

I would be happy to support any organization which works effectively to eliminate the Deminimus.

I will kiss the feet of the leader of any organization that works to require that AMC fees be disclosed and that AMC's must comply with USPAP.

Any takers?
I would join in a heart beat.
 
Joined
Nov 7, 2005
Professional Status
Certified Residential Appraiser
State
Florida
http://www.FDIC.gov/consumers/loans/loanmod/FDICLoanMod.pdf
The link is greater explanation of the plan.
Pg 12
"Current Property Value is determined by an interior appraisal, Broker Price Opinion
(BPO), Automated Valuation Model (AVM), or original appraisal value adjusted by
MSA level home price change to date. This value is then adjusted by forecasted MSA
level home price changes."

At least appraisals are mentioned in this version, but the intention for the lenders to use BPOs to save money is clear in their press release.
 

Summer

Member
Joined
Jan 2, 2008
Professional Status
Certified Residential Appraiser
State
Connecticut
The top guy at AI in CT wants to know how AMCs will make money if they can't take the appraisers fee. What is up with that?
 

mopickled

Senior Member
Joined
Dec 6, 2007
Professional Status
Certified Residential Appraiser
State
North Carolina
The top guy at AI in CT wants to know how AMCs will make money if they can't take the appraisers fee. What is up with that?

This Little Guy wants to know how we are supposed to run an unbiased profession while being gang r*ped?? What is up with that?? :icon_idea:
 
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