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Got it. So, if someone asks you to consider alternative sales data, which is specifically allowed in TILA, you are going to claim a TILA violation. Who could possibly argue with logic like that? :rof:
Depends on the the alternative sales data :)

These must be appropriate comparables, not higher priced sales sent over for their higher price point to target a value, otherwise the lender is in violation where they are (3) seeking to influence an appraiser or otherwise to encourage a targeted value in order to facilitate the making or pricing of the transaction;

(3) Permitted actions. Examples of actions that do not violate paragraph (c)(1) or (c)(2) include: (i) Asking a person that prepares a valuation to consider additional, appropriate property information, including information about comparable properties, to make or support a valuation;
 
Got it. So, if someone asks you to consider alternative sales data, which is specifically allowed in TILA, you are going to claim a TILA violation. Who could possibly argue with logic like that? :rof:


Why don't you honestly tell everyone,

Why you cite what was only valid for 90 days in 2010,

when obviously, you know what is applicable and current today?

.
 
Depends on the the alternative sales data :)

These must be appropriate comparables, not higher priced sales sent over for their higher price point to target a value, otherwise the lender is in violation where they are (3) seeking to influence an appraiser or otherwise to encourage a targeted value in order to facilitate the making or pricing of the transaction;

(3) Permitted actions. Examples of actions that do not violate paragraph (c)(1) or (c)(2) include: (i) Asking a person that prepares a valuation to consider additional, appropriate property information, including information about comparable properties, to make or support a valuation;

Well, you need to take that up with M - SHE is the one claiming that asking one to consider ANY alternative sales data is a violation - not me :)
 
Well, you need to take that up with M - SHE is the one claiming that asking one to consider ANY alternative sales data is a violation - not me :)


How come you don't answer my question of:

Why you cite something that was valid only for 90 days in 2010,
when you obviously know what is applicable and current as of today?


.
 
Well, you need to take that up with M - SHE is the one claiming that asking one to consider ANY alternative sales data is a violation - not me :)
ahhh...but that is the mantra that you keep saying. I pointed that out recently when you tried to pin that on me. You are the one that never distinguishes between sending appropriate comparables and higher priced sales sent over for their higher price point to target a value.

How come you don't answer my question of:
Why you cite something that was valid only for 90 days in 2010,
when you obviously know what is applicable and current as of today?
I'd like to know your thoughts on that, too :)
 
ahhh...but that is the mantra that you keep saying. I pointed that out recently when you tried to pin that on me. You are the one that never distinguishes between sending appropriate comparables and higher priced sales sent over for their higher price point to target a value.


I'd like to know your thoughts on that, too :)
My thoughts? My thoughts are that this is OK - Asking a person that prepares a valuation to consider additional, appropriate property information, including information about comparable properties, to make or support a valuation

You want to apply a stricter test/standard Fine. If your clients are good with that, I could not possibly care any less. As I said before, I think trying to amend and/or append assignment conditions by sneaking additional things into a report that have no business being there is highly unprofessional. But that is just my opinion. You obviously have a different view. i just would like to see how you would react if a client turned the tables and tried to do such a thing to you :)

 
Depends on the the alternative sales data :)

These must be appropriate comparables, not higher priced sales sent over for their higher price point to target a value, otherwise the lender is in violation where they are (3) seeking to influence an appraiser or otherwise to encourage a targeted value in order to facilitate the making or pricing of the transaction;

(3) Permitted actions. Examples of actions that do not violate paragraph (c)(1) or (c)(2) include: (i) Asking a person that prepares a valuation to consider additional, appropriate property information, including information about comparable properties, to make or support a valuation;


That opens a whole new can of worms.

Like practicing appraisal without a license. Truth in lending comes back though and antitrust and public trust.
 
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