Jeff has been in the mortgage industry for thirty-five years, with more than twenty five years’ experience as an appraiser (he is a Certified Residential Appraiser in 15 states). With Notes from the Regulatory Road, Jeff will provide timely commentary on what is happening in the industry.
Information is the key to making sensible decisions. In our industry, the sheer number of new rules and regulations are staggering. This week I’ve spent time with others working towards making informed decisions in the best interest of our industry. Here’s what I’ve been up to:
AMC Appraisal Fees in North Carolina
On April 7th I met with members of the North Carolina Legislature, the North Carolina Attorney General’s Office and members of the North Carolina Appraiser Coalition. Our discussions were focused on Customary & Reasonable (C&R) appraisal fees.
The interim final rule, required by the Dodd-Frank Wall Street Reform and Consumer Protection Act, gives two options on how to comply with C&R. North Carolina was contemplating a bill that would have limited compliance to a single option. During discussions it was noted that the North Carolina appraisal board currently does not have statutory authority to enforce C&R at any level.
In the end all parties agreed that the bill needs to simply say that an AMC operating in the state must comply with the federal rule outlined in TILA 129e, as well as the Interim Final Rule outlining both presumptions of compliance.
Pro Teck supports paying customary and reasonable appraisal fees, and believes that paying a competitive fee to appraisers who provide quality work and reliable service is just good business. Once the bill is passed the board will draft formal rules.
Progress in Phoenix
From April 8-10th I was at the Association of Appraiser Regulatory Officials (AARO) Conference in Phoenix, AZ. On Sunday I presented a session regarding the onboarding and maintenance of an AMC’s Appraisal Panel. The discussion was very well received and provided a tremendous amount of information about the roles and responsibilities of an AMC that the regulators were not aware of previously, including how we are contractually obligated by many clients to use the appraiser with the best quality score, regardless of price.
I have been attending the AARO conference for the past six years, pre Dodd/Frank. The level of collaboration between all parties involved lately has been impressive. With all the changes that have happened and continue to happen, it’s good to see all parties working together to make sensible decisions.
Expanding on the Issues in D.C.
Finally, on April 19-20th, I was on Capitol Hill with members of the Real Estate Valuation Advocacy Association (REVAA) meeting with Senate and House staffers, including members of the House Financial Services Committee. We discussed the issues most important to the future viability of our industry, including ensuring reasonable and responsible regulation that ensure availability, efficiency and reliability of real estate valuation products and services. I’ll share more of what I learned in the next Notes from the Regulatory Road!