Voice Of Appraisal

[Eli]

that makes perfect sense... i'm sure the LA real estate board, who can no longer make any decisions without it first being reviewed by someone else, knows more about antitrust than the FTC.

Sorry, they have more data relative to antitrust law than the FTC has relative to the profession. Naturally.

They will feed the FTC. Antitrust law is very deep and it focuses on the public and individual. Antitrust law is way deeper than the FTC's allegations against LA.

The FTC knows that too! LA does too!

The data will go through the AG. Now, I assume there will be informal conversations going on. Lol

It is a major game changer them shifting it to the AG because the AG can stand on somewhat equal ground to the FTC on antitrust law within their boundaries. Pretty much equal power within their boundaries and LA has more data within their boundaries.

 

[residentialguy]

Don't worry, the Govt has a clear plan.

 

[Meandering]

Aint that the truth!

But look what you did.

Here's the pop up ad below your post.

 

[BRCJR]

I agree, Joe.
Many of us believe the current "general" AMC model is not sustainable.
Look at their history:

• ......................................................................................................................
• 
  
• Pre-HVCC, it should be remembered that there were a number of small-to=medium sized residential fee shops. I had one (15 appraisers and a staff of 5 support). Pre-HVCC, we were the largest vendor for WAMU (pre-AMC for them) in the SF Bay Area. I had a similar relationship with US Bank. Back in the day, they would engage our firm and because of the personal/professional relationship I had developed and would rely on me to ensure that the appraisers we used were qualified and competent. That isn't unique to me; that is the way it was.
• ...............................................................................................................................................................

The world according to Denis!

Per IAEG, An institution or its agent must directly select and engage appraisers......................Where you (their agent) acting as an AMC?

The comment, bolded, above indicates those entities were letting you pick their Appraiser for their assignments to your firm.

 

[Eli]

Don't worry, the Govt has a clear plan.
View attachment 32989

No! La is the ticket. I have a feeling the wheels are rolling. This BS won't last long. I know it has lasted a long time. Every dog has their day!

Appraisers are like Timex. They just keep on ticking.

 

[hastalavista]

Where you (their agent) acting as an AMC?

Acting as an AMC? No.
My arrangement with the clients was pre-HVCC/Dodd-Frank. I said I was a fee shop, not an AMC (but I noted that under the current regulations, if my company existed as it did then, it would have to be registered as an AMC).

The comment, bolded, above indicates those entities were letting you pick their Appraiser for their assignments to your firm.

They approved my firm. Any appraiser that worked within my firm (fully licensed) was approved by them and they (the client) accepted the appraisal.

 

[BRCJR]

Acting as an AMC? No.
My arrangement with the clients was pre-HVCC/Dodd-Frank. I said I was a fee shop, not an AMC (but I noted that under the current regulations, if my company existed as it did then, it would have to be registered as an AMC).


They approved my firm. Any appraiser that worked within my firm (fully licensed) was approved by them and they (the client) accepted the appraisal.

They were allowing you to "pick" the Appraiser based upon your comment. You did nothing wrong but, those entities were not following regulations unless you were their agent or employee. That requirement was in place before the HVCC.

 

[TRESinc]

They were allowing you to "pick" the Appraiser based upon your comment. You did nothing wrong but, those entities were not following regulations unless you were their agent or employee. That requirement was in place before the HVCC.

i don't see it that way. if every appraiser that worked for denis' company was already approved by the lender where is the issue? that's how all shops worked - get the staff approved by a client and then assign the order as needed.

 

[hastalavista]

They were allowing you to "pick" the Appraiser based upon your comment. You did nothing wrong but, those entities were not following regulations unless you were their agent or employee. That requirement was in place before the HVCC.

No, I wasn't their agent or employee.
I wouldn't argue with you that by today's standards, there would be a significant issue.
I would say that 15 years ago, approving a "firm" was very common. And, interestingly enough, 15 years ago, there was no AMC (at least in my business model) so all the appraisals that were produced by my firm went direct to the lender who then did their review on each report. In that respect, the QC/review process (obviously I'd like to think that the QC we did internally was very good) performed by the lender was fairly significant and assignment-specific.

 

[BRCJR]

No, I wasn't their agent or employee.
I wouldn't argue with you that by today's standards, there would be a significant issue.
I would say that 15 years ago, approving a "firm" was very common. And, interestingly enough, 15 years ago, there was no AMC (at least in my business model) so all the appraisals that were produced by my firm went direct to the lender who then did their review on each report. In that respect, the QC/review process (obviously I'd like to think that the QC we did internally was very good) performed by the lender was fairly significant and assignment-specific.

"Today's standards" regarding appraiser selection have been in place since 1994. It may have been common practice but, it was still a violation of the IAEG. I understand many did not even know what IAEG was until December 2, 2010 when D-F put them on the map.