• Welcome to AppraisersForum.com, the premier online community for the discussion of real estate appraisal. Register a free account to be able to post and unlock additional forums and features.

Illegal In House Valuations

Ive shown you the nc law. You only want to argue it.

Here’s the facts, the laws are written, they are not enforced. Your buddy on here is one that played a part in making sure they weren’t enforced.

Honestly, is it really your position that they wrote laws to create a middleman and then didn’t intend on having them be middle men?
 
The banking regs and laws were written to separate the loan production side from the due diligence side. AMCs don't do loan production. There is no appraiser-independence conflict of interest at the AMCs.

One more thing - the laws weren't written to "create" AMCs. AMCs existed prior to the HVCC and I still remember when most of them employed their own internal staff appraisers and reviewers. The big ones in this region all started off as fee shops.

Moreover, the laws were also not written to give the AMCs anything. The only thing that happened with the laws is that they prohibited the lenders from using MB-controlled appraisals; and then they finally brought the AMCs under regulation. That's it. The appraiser independence regs for the in-house appraisal depts had already been on the books since the 1990s. Those were created for the lenders via FIRREA, not the HVCC or D-F.
 
Last edited:
prevent the mortgage brokers from ordering an appraisal... :unsure: it is better now, the mortgage broker can estimate value via waivers no appraiser needed more kool aid please:rof:
 
Joe Flacco said:
I think big banks lending their own money should be allowed to take valuations back in house. They should be able to do it in house without full blown appraisals. The whole collateral risk management model should be overhauled. What we are doing now is basically the same as it was pre-internet with the main changes over time being who communicates and engages with who. The model is way outdated for 2025.
Click to expand...
They are.
 
djd09 said:
prevent the mortgage brokers from ordering an appraisal... :unsure: it is better now, the mortgage broker can estimate value via waivers no appraiser needed more kool aid please:rof:
Click to expand...
Mortgage brokers are part of loan production, just like in-house loan officers who were explicitly cut out of the loop at the lenders via FIRREA.

They have no legitimate business even touching an appraisal report until after it's been completed and accepted by the lender. No business even speaking to an appraiser, much less controlling the assignment.

The appraisal is literally none of their business.
 
The GSEs are making their decisions off their AVMs. That's why they call summarize their Value Acceptance process as "data, model and technology driven" and not "MB estimate driven". Similar to how they summarize their "value determination" side as being appraisal driven. Not MB-estimate driven.

1760185697512.png

The MBs role is to sell the dream. Not underwrite the loan or control the appraisal.
 
Last edited:

Table of Contents​

  1. Bank Fines: The 15 Biggest Compliance Fines
  2. 1. Binance Violates the Banking Secrecy Act — $4.3 Billion
  3. 2. The AML Program That Wasn’t — $1.256 Billion
  4. 3. The MAN Group’s Poor Trading Oversight — $1.312 Billion
  5. 4. JPMorgan Chase & the Biggest Ponzi Scheme — $1.7 Billion
  6. 5. SAC Capital Advisors & Insider Trading — $1.8 Billion
  7. 6. Credit Suisse & Tax Fraud — $2.5 Billion
  8. 7. LIBOR Price-Fixing Scandal — $2.5 Billion
  9. 8. Wells Fargo’s Phantom Accounts — $3 Billion
  10. 9. Wells Fargo & Rampant Mismanagement — $3.7 Billion
  11. 10. Credit Suisse’s Toxic Asset Sell-Off — $5.3 Billion
  12. 11. Goldman Sachs & the Pilfered Malaysian Coffers — $5.4 Billion
  13. 12. Deutsche Bank & SMC — $7.2 Billion
  14. 13. BNP Paribas’ Money Laundering — $8.973 Billion
  15. 14. JPMorgan Chase & SMC — $13 Billion
  16. 15. Bank of America & SMC — $30.6 Billion
  17. 16. TD Sets Aside $2.6 Billion Ahead of Expected Compliance Fines
  18. 17. Danske Bank – Over $2 Billion
  19. Compliance Software to Keep You Protected
www.enzuzo.com

17 Biggest Compliance Fines ($1Billion and Above)

Look at the biggest compliance & bank fines from 2012 to 2022, involving Western financial institutions like the Bank of America, JP Morgan, and more.
www.enzuzo.com www.enzuzo.com

yes more in house valuations...what could go wrong:rof:
 
I didn't say they couldn't be wrong. I'm just taking note of what they say they are doing.
 
You must log in or register to reply here.
Find a Real Estate Appraiser - Enter Zip Code

Copyright © 2000-, AppraisersForum.com, All Rights Reserved
AppraisersForum.com is proudly hosted by the folks at AppraiserSites.com
Back
Top