• 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.

OCC, FDIC, Lender Chief Compliance Officers Asleep at the Helm

Status
Not open for further replies.

Mike Kennedy

Thread Starter
Elite Member
Joined
Sep 28, 2003
Professional Status
Certified Residential Appraiser
State
New York
Announcement 2005

The Office of the Comptroller of the Currency, otherwise known as the U.S. Treasury, has just released new standards on residential loan practices, which make it clear that any attempt to influence the independent judgment of a real estate appraiser violates federal standards.

The standards are an appendix to part 30 of its "regulations, guidelines, concerning the residential mortgage lending practices of national banks and their operating subsidiaries" to protect against "predatory, abusive, unfair, or deceptive residential mortgage lending practices." The standards are enforceable pursuant to section 39 of the Federal Deposit Insurance Act and the "implicating process set forth in part 30 of the OCC's regulations."

Key for appraisers who have been complaining that they are being forced to meet high asking prices that are not substantiated by comparables and other practices is the reiteration of what should already be known to bankers:

".....the bank must be able to effectively to manage the various risks, including credit, legal, compliance, and reputation risks....the bank must not become engaged in abusive, predatory unfair, or deceptive practices, directly, indirectly through mortgage brokers OR OTHER INTERMEDIARIES, or through purchased loans."

On page 14, the standards say, "In addition, national banks and their operating subsidiaries must comply with the requirements and Guidelines affecting appraisals of residential mortgage loans and appraiser independence.

12 CFR part 34, subpart C, and the Interagency Appraisal and Evaluation Guidelines (OCC Advisory Letter 2003 - 9 (October 28, 2003)). For example, engaging in a practice of influencing the independent judgment of an appraiser with respect to a valuation of real estate that is to be security for a residential mortgage loan would violate applicable standards.
 
Joined
Jan 13, 2002
Professional Status
Retired Appraiser
State
Florida
Everybody involved CHOSE ignore the laws, rules, and regulation.

Now, they're all getting caught and scrambling to figure out how to get out of it.
 

Fred

Elite Member
Joined
Jan 15, 2002
Professional Status
Retired Appraiser
State
Virgin Islands
No problem. They'll just hop into their black helipcopters. :)
 

Joyce Potts

Elite Member
Supporting Member
Joined
Feb 6, 2005
Professional Status
Certified Residential Appraiser
State
Florida
BLAH, BLAH and BLAH. They all knew what was happening. They have NO intention of changing anything. There will be a few dog and pony shows, but the lending industry is simply biding it's time before the market turns around so the same methods can reap them billions in profits.
 

Frederick

Senior Member
Joined
Nov 2, 2005
Professional Status
Certified General Appraiser
State
New Jersey
BLAH, BLAH and BLAH. They all knew what was happening. They have NO intention of changing anything. There will be a few dog and pony shows, but the lending industry is simply biding it's time before the market turns around so the same methods can reap them billions in profits.


After the past few months they sure do have a lot of ground to make up to get those billions back. A lot of them are not coming back from the grave to do it.
 

fritzvogel

Senior Member
Joined
Dec 16, 2004
Professional Status
Certified Residential Appraiser
State
New York
That was 2005?.....I guess they didn't get around to reading it yet.
 

Workbox

Elite Member
Joined
Mar 2, 2005
Professional Status
Certified Residential Appraiser
State
Colorado
Somebody was mentioning about a rotation appraisal list for the county they live in..........I would say 2 year minimum living in that county.
 
Last edited:

Ray Miller

Elite Member
Joined
Feb 20, 2002
Professional Status
Licensed Appraiser
State
Wisconsin
I will believe it when I see and hear it happening. That will be when the lenders stop asking for comp checks, they pay a fee that an appraiser can live by.

I think it is just more lip service from big brother.

Today, I have been ask meet the value if I want the order three times on my cell phone.

I had one lender call me and yap because his owner said his house is worth $380K by another appraiser. Yet I only brought it in at $250K and the highest selling home similar to his in the rural county was $267K

Cell phone is going to be off all day tomorrow at the show for sure.

Now it time to go watch those tight butt phony cowgrils prance up and down the runway. At least we will be getting a steak dinner out of the fashion show. Night all.
 

hglenbetts

Senior Member
Joined
Dec 3, 2007
Professional Status
Certified Residential Appraiser
State
Michigan
No problem. They'll just hop into their black helipcopters. :)

Hay, don't say that out loud. I live in the town where they tore down the horse barn looking for Jimmy Hoffa. The BLACK HELICOPTERS were all over the place.
Did you ever here of swamp gas. I saw them then too.:rof: :rof: :rof:
 

Elliott

Elite Member
Joined
Apr 23, 2002
Professional Status
Certified General Appraiser
State
Oregon
I truly hope someone with some intelligence will go through the
archieves of this board and read the warning signs that were
frequently given for the last 5 years and ignored.
 
Status
Not open for further replies.
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
Top

AdBlock Detected

We get it, advertisements are annoying!

Sure, ad-blocking software does a great job at blocking ads, but it also blocks useful features of our website. For the best site experience please disable your AdBlocker.

I've Disabled AdBlock
No Thanks