2010 IAG and Commercial Appraisals

When the 2010 Interagency Appraisal and Evaluation Guidelines were printed in December of 2010 there were many new requirements and a restating of many old ones. 

Section VIII Minimum Appraisal Standards at the top of Page 9 of 45 states:

 

Disclosing the Appraisal Management Fee separate from the Appraisal Fee?

SAMCO’s clients disclose appraisal costs in two different ways on the Good Faith Estimate and initial Truth in Lending Disclosure (both being replaced by the new CFPB Loan Estimate in August 2015).  The first is to total both the appraisal management fee and appraisal fee into one total cost.  The second is to separate and identify the two individual fees to the consumer.  

Disclosing the Appraisal Management Fee separate from the Appraisal Fee?

SAMCO’s clients disclose appraisal costs in two different ways on the Good Faith Estimate and initial Truth in Lending Disclosure (both being replaced by the new CFPB Loan Estimate in August 2015).  The first is to total both the appraisal management fee and appraisal fee into one total cost.  The second is to separate and identify the two individual fees to the consumer.  

It's a Wrap for 2013!

It’s a Wrap for 2013!
And it’s not just a New Year, but an opportunity for a New, Smarter and Easier Way!
Change can happen slowly or quickly. With banking regulations, it tends to be on the slower side. Take for example the 2010 Interagency Appraisal and Evaluation Guidelines. They were finalized and announced in December 2010, but there has been so much turmoil in the finance world the past years that examination teams are just now starting to make these changes part of their examination process! That’s slow!!

Fannie Mae Addresses Appraisal Quality

A Fannie Mae Dec. 10 letter to lenders addressed appraisal quality, appraiser selection requirements, data quality issues and new processes to identify and monitor appraisers.  Fannie Mae stated that there are appraisals being completed by appraisers who have has their license suspended or revoked.  Fannie also reminded lenders that patterrns of discrepancy and inconsistancies in physical data are occuring and that Fannie reviews for that.  Fannie will be contacting the appraiser directly about inconsistancies or errors.  See the Dec. 10 Fannie Mae Letter.  https://www.fanniemae.com/content/announcement/ll1310.pdf

SAMCO's Bulletin Board Ezine

The SAMCO Bulletin Board is an ezine (electronic newsletter) sent to SAMCO’s approved appraisers, community bank processing departments, and community bank underwriting staff.  The SAMCO Bulletin Board has information on regulatory changes in the mortgage and banking industry or explanations of USPAP or Appraisal Standards and how they affect the writing of an appraisal report.  SAMCO does not have a computerized audit system.  Experienced, USPAP trained staff personally audit each individual appraisal to ensure that it meets not only USPAP and Appraisal Standards, but the individual requirements of each of our community bank clients.  And this is important!  

 

COMPLIANCE STRATEGY FOR DODD-FRANK

Do you feel like you’re being buried under not just new regulations, but the paperwork that accompanies it?  When it comes to compliant appraisal policies and procedures many community bank lenders believe they are compliant now, or at the least, believe they know what to do to become compliant.  But so many regulations have changed that touching all the bases can be difficult.  The Consumer Financial Protection Bureau (CFPB) is moving towards enforcement and oversight, and penalties that will make everyone take notice.

One of the many regulations that the CFPB is charged to oversee is the Equal Credit Opportunity Act (ECOA). One existing ECOA appraisal rule is:

Third Party Vendor Due Diligence (Or Risk Management)

Every day regulatory agencies are spitting out new regulations for community banks. And it will only become more challenging as Dodd-Frank and the CFPB swing into full regulatory mode and as the other agencies (Federal Reserve, FDIC, OCC, NCUA) play ‘catch up’ with training on these new regulations. Lenders are being constantly challenged to find new and better ways to serve their community within these new compliance issues, while maintaining profit.

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About Us

SAMCO Appraisal Management Company is a nationwide appraisal management service for community banks. We provide regulatory compliance and save our clients actual dollars at the end of the day.

SAMCO is committed to earning your loyalty one appraisal at a time.

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