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Interagency Appraisal and Evaluation Guidelines

Posted by Carl Streck on Wed, Sep 18, 2013 @ 10:09 AM

The revised Interagency Appraisal and Evaluation Guidelines, published in December 2010, actually were not issued as a result of Dodd-Frank; they exist separate and independent of Dodd-Frank. They were proposed in 2008, two years before Dodd-Frank, and finalized just after Dodd-Frank.

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Tags: appraisal management company, Appraisal Management Companies, dodd-frank, Appraisal and Evaluation Guidelines

GAO’s Involvement

Posted by Carl Streck on Mon, Sep 16, 2013 @ 10:09 AM

One of the things Dodd-Frank did was task the U.S. Government Accountability Office (GAO) with writing two reports to Congress in which they were critical of the oversight of state appraisal boards and appraisers.

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Tags: appraisal management company, Appraisal Management, Appraisal Management Companies, dodd-frank, GAO

Condition of Property

Posted by Carl Streck on Wed, Jul 10, 2013 @ 10:07 AM

If you’re doing evaluations internally, you need to think about how you are getting information on physical condition. The term “average condition” is frowned upon, especially if it’s unsupported and assumed.

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Tags: appraisal management company, Appraisal Management, Appraisal Management Companies, dodd-frank, evaluations, BPO, broker price opinions, physical condition

What Should an Evaluation Include?

Posted by Carl Streck on Fri, Jul 05, 2013 @ 10:07 AM

In many cases, standard operating procedures for evaluations that were once considered acceptable to regulators are now deemed wholly unacceptable, due to Dodd-Frank.

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Tags: appraisal management company, Appraisal Management, Appraisal Management Companies, validation, dodd-frank, evaluations

The Review Process

Posted by Carl Streck on Tue, May 28, 2013 @ 10:05 AM

There is a mandate that all evaluations and appraisals be reviewed prior to the final credit decision. Worth noting is an expectation on the part of the regulator that the person who does the evaluation has the appropriate education, experience and competence, specifically with respect to the property type, the risk and the complexity involved in the transaction.

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Tags: appraisal management company, Appraisal Management, Appraisal Management Companies, dodd-frank, evaluations, Appraisal and Evaluation Guidelines, review

Get Your Free Copies

Posted by Carl Streck on Tue, May 21, 2013 @ 10:05 AM

One consumer protection regulation that will impact how you perform evaluations on the residential side is Dodd-Frank's Section 1474: Equal Credit Opportunity Act (ECOA) § 701(e), an amendment requiring a free copy of an appraisal/valuation.

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Tags: appraisal management company, Appraisal Management, Appraisal Management Companies, dodd-frank, evaluations, Appraisal and Evaluation Guidelines, consumer protection, Appraisal Compliance

Compliance Guides for Dodd-Frank Appraisal Rules

Posted by Nathan Brown on Fri, May 03, 2013 @ 07:05 AM

Late yesterday, the CFPB published compliance guides for its ECOA Valuations Rule and the TILA Higher-Priced Mortgage Loans (HPML) Appraisal Rule.  Both rules were finalized in January of this year and take effect in January of 2014.

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Tags: dodd-frank, TILA, CFPB, ECOA, appraisal rule, HPML

Best Practices when working with appraisers

Posted by Carl Streck on Thu, Apr 11, 2013 @ 10:04 AM

Appraiser Blacklisting and Defamation

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Tags: appraisal review, dodd-frank, FIRREA, appraisal threshold, TILA, FHFA, fannie mae, section 129H, super appraisal, higher risk mortgage, section 1471, CFPB, Appraisal Regulations, OCC, FDIC

Three Predictions for Your Next Regulatory Exam

Posted by Nathan Brown on Wed, Apr 10, 2013 @ 11:04 AM

Three Predictions for Your Next Regulatory Exam

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Tags: appraisal regulation, dodd-frank, FIRREA, CFPB, OCC, FDIC, ECOA, Appraisal Compliance, Appraisal Exam, Regulation B

Overview of the New Higher-Risk Mortgage Loan Requirements

Posted by Nathan Brown on Mon, Aug 20, 2012 @ 08:08 AM

In a blog post last week, we alerted you that the agencies had released a new, 211-page proposal to implement Dodd-Frank Section 1471, which added Section 129H to the Truth in Lending Act.  That section imposes tougher appraisal requirements on higher-risk mortgage loans.  The next day, we circulated our preliminary analysis of the proposal. 

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Tags: appraisal review, dodd-frank, FIRREA, appraisal threshold, TILA, FHFA, fannie mae, section 129H, super appraisal, higher risk mortgage, section 1471, CFPB, Appraisal Regulations, OCC, FDIC