Eli
Elite Member
- Joined
- May 12, 2007
- Professional Status
- Certified General Appraiser
- State
- Tennessee
everyone has access to the LA budget problems. it's a matter of public record.
Ok, what does that have to do with anything?
everyone has access to the LA budget problems. it's a matter of public record.
no one, other than you, has specifically talked about the funds of the LA real estate board. if you think that they have enough funds to fight a case against the FTC on their own, or any real estate board in any of the 55 territories/states, then i have a bridge in NY and some waterfront property in FL to sell you - cheap!
the board is part of the state, who would have to pay the legal bills for fighting the case. it's painfully obvious they either
A - don't have the funds to fight the case to the governor stepped in and squashed it
or
B - won't be able to win the case so the governor stepped in and squashed it
take your pick.
Ok, what does that have to do with anything?
Yeah right!
They act like,
just cause the state is broke,
it's not making payroll or something.
.









Because this becomes more of an issue with the Trid update, as the borrower can only be charged the "average" of appraisal fees. Not the "cost" of appraisal fees,
.
From your own post on the topic:
3. Uniform use. If a creditor chooses to use an average charge for a settlement service for a particular loan within a class, § 1026.19(f)(3)(ii)(C) requires the creditor to use that average charge for that service on all loans within the class. For example:
i. Assume a creditor elects to use an average charge for appraisal fees. The creditor defines a class of transactions as all fixed rate loans originated between January 1 and April 30 secured by real property or a cooperative unit located within a particular metropolitan statistical area. The creditor must then charge the average appraisal charge to all consumers obtaining fixed rate loans originated between May 1 and August 30 secured by real property or a cooperative unit located within the same metropolitan statistical area.
Where does it mandate use of average fees? It says that if one uses an average fee for a particular loan in a class loan then they must use the average on all loans in that class. It mandates consistency but does not mandate use of the average. n'est pas?
This ought to be good. I am sure that the coming answer probably won't be some rambling, disjointed bunch of bits and pieces from different laws and regulations haphazardly pasted together in some non-nonsensical manner that in no way answers or are relevant to your post or anything like that, lolLet us all know when you get that time machine built.Instead of moving forward, we should go BACK and put the AMC in the correct line. Then we can make progress in this profession.
And to those on the outside reading this forum. Hear this, the system is screwed up!!!