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July 27th, 2016 9:22 PM

An AMC sent an appraiser the following email this morning: 

 ".....customary and reasonable fees are compliant under Virginia presumption that rates are based on recent rates paid to a representative sample of providers of appraisal services in the geographic market based on the fee schedules of these providers. Please complete the attached form and submit to: “

Wow are they confused about customary and reasonable feesThis is a severe twist on Virginia Regulations for customary and reasonable fee compensation to appraisers.  Virginia Law mirrors the language in the TILA. They are essentially the same.  The verbiage in the email sent to appraisers by this AMC is just WRONG!

The Virginia Real Estate Appraiser board attempted to make things easy for AMCs.  On February 23, 2016 the Virginia Real Estate Appraiser Board adopted the United States Department of Veterans Affairs’ Roanoke Regional Loan Center Appraisal and Inspection Fees Schedule as a presumption of compliance. This was a gift to the AMC’s, but I guess some just don’t want to accept it..

 The Virginia Real Estate Appraiser Board created a Guidance Document for AMCs and appraisers to help understand the law. VaCAP sent a copy of the Guidance Document  via email and US Mail to the address of record for each AMC licensed to operate in Virginia.  As AMCs did not like this clear guidance, they began to twist things around, or just ignore the parts of the legislation they did not like.

 As many were still confused, or trying to avoid paying appraisers a customary and reasonable fee, the Virginia Real Estate Appraiser Board published additional guidance on DPOR’s website. They in turn sent this additional clarification along with a copy of the original Guidance Document to each AMC and appraiser licensed to operate in Virginia.  

The Virginia Real Estate Appraiser Board has gone out of its way
 to help the AMCs. ... It boggles the mind why some refuse to accept it!

And here we are today…..  The final rules have commentary associated with them explaining each and every provision of the Dodd-Frank Act including customary and reasonable compensation to fee appraisers. Even if you don’t like the rules, we all must follow them.

 Click Here to see exactly where this AMC falls short!

Please tell us what you think.

Posted in:Customary and Reasonable fees and tagged: AMC
Posted by Virginia Coalition of Appraiser Professionals on July 27th, 2016 9:22 PMView Comments (2)

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May 1st, 2016 5:54 PM
What is the best way to ensure you receive
 a customary and reasonable fee
 for an appraisal?

Only accept assignments with a customary and reasonable fee!  

That being said, here is a reminder of a USPAP requirement to consider before you respond to that email or text blast....

 Scope of Work Rule
  1. Identify the problem to be solved.
  2. Determine and perform the scope of work necessary to develop credible assignment results.
  3. Disclose the scope of work in the report.
 Comment: Scope of work includes, but is not limited to:
  • the extent to which the property is identified;
  • the extent to which tangible property is inspected;
  • the type and extent of data researched; and
  • the type and extent of analyses applied to arrive at opinions or conclusions.
Before responding to the email or text blast, do you have enough information to comply with USPAP and determine the scope of work?  Are there any unusual circumstances with the subject? Easements? Pending zoning change? Unique property? Illegal use?  Does this AMC always kick back the report for revisions?  Consider the following before accepting the fee offered as customary and reasonable from an email or text blast...... 

Are you receiving requests from lenders for specific statements regarding your FHA property observations? Underwriters are looking for statements in the appraisal certifying that all FHA property observation procedures were performed  by the appraiser.  Examples of this type of request are below:
FHA Appraisal Lender requests:

Lender 1: Can you also please state that the power/water was on and functioning properly and that you tested all the appliances & mechanicals.

Lender 2: Message: Thank you for the report. Due to increased scrutiny by our investors, there are some additional items which need to be addressed. Could you please provide the following: Per Handbook 4000.1, a head and shoulders inspection of the attic is only permissible if there is scuttle access. Per page 1, you indicate that there is a drop stair attic. Please advise/confirm if you entered the attic to complete a full visual inspection. (Unfortunately, the photo alone cannot confirm this).
Lender 3: Please add comments to confirm that a full inspection of the attic area was conducted. The photo is included, but comments are also requested to confirm full inspection was completed.

Appliances take time to operate. Attic and crawl space inspections take time to complete. 
Please review the Appliance Observation Requirement in HUD Handbook 4000.1 pg. 486. Are you demanding a customary and reasonable fee for your time? 

As professional valuation experts, we all need to decide what a customary and reasonable fee is for the assignment.  Be aware of FHA requirements. Be Professional. Provide a valuable service to the consumer, the lender and FHA.  Be proud of your work and get the fee you deserve! 

News from the National Association of Realtors®

On Wednesday May 11, 2016 the 2016 Real Property Valuation Committee of the National Association of Realtors® will meet in Washington DC.  All Realtor® members are invited to attend. 
See the details of the meeting here. 

On March 18, 2016, NAR sent this letter to HUD concerning FHA appraisal requirements. 

and a little closer to home..... 

VaCAP has learned within the past week 3 AMCs attempting to do business in Virginia without a license. Make sure you check DPOR's site to confirm the AMC has a license. Neither you, nor the consumer has any protection from an unlicensed AMC. Find a list of licensed  AMC's here. 

If the transaction is a purchase, YOU ARE OBLIGATED TO PROTECT THE CONSUMER. Notify the agents involved immediately that the AMC ordering the appraisal is not licensed. They are on your side and want the deal to go through. You also have an obligation to file a complaint against the AMC with DPOR. You can do this anonymously byclicking here.  DPOR will attempt to bring the AMC in to compliance. 

Posted by Virginia Coalition of Appraiser Professionals on May 1st, 2016 5:54 PMLeave a Comment

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