Working With New Appraisal Independence Requirements
A major shakeup in appraisal rules started with the controversial 2009 Home Valuation Code of Conduct. The HVCC disrupted the traditional relationships between appraisers and mortgage originators by eliminating mortgage brokers from the process.
Beyond the HVCC and affecting all mortgage lending, the Federal Reserve in October 2010 issued an interim final rule on appraisal independence as required by the Dodd-Frank Act. Industry expressed concerns regarding the Fed’s “customary and reasonable” fee provisions. However, efforts to delay or repeal the Fed’s interim final rule were denied and it is now in effect.
Appraisal systems encountered a third shift when Fannie Mae, Freddie Mac and the FHA implemented standardized appraisal data requirements.
Find out everything you need to know about these data requirements—called the Uniform Appraisal Dataset—and other issues impacting appraisals in Working With New Appraisal Independence Requirements. You’ll learn about the impact on consumers, what should be in your appraisal and evaluation program, what the prohibitions are, and more. This new Guide will help you get up-to-speed on all the details.
Dodd-Frank Act Requirements
- Use of Appraisal Management Companies
- Registration Fees & Timeline
- Community Banks
- AVMs and Broker Price Opinions
- Higher-Risk Mortgages
- RESPA Appraisal Disclosure
- Impact on Borrowers
Federal Reserve Regulations
- Covered Transactions
- Customary and Reasonable Fees
- Presumptions of Compliance
- Fee Schedules and Studies
- Industry Concerns
- Mandatory Reporting of Violations
- Outlook
Federal Guidelines
- Selection of Appraisers
- Approved Appraiser List
- Engagement Letters
- Appraisal Standards for Loss Mitigation Activities
- AVMs and Broker Price Opinions
- FDIC Lawsuits
Fannie & Freddie Guidelines
- AIR Guidelines
- Allowed Broker Activities
- Penalties and Compliance
- Applicability to Loss Mitigation
- Differences Between HVCC and AIR
- Uniform Mortgage Data Program
- Uniform Appraisal Data Set
- UMDP Effective Data
FHA Guidelines
- Broker Prohibition
- AMC/Third-Party Fees
- Customary and Reasonable Fees
- Influence of Appraisers
- Reporting to the FHA
- Second Appraisals
- FHA Adoption of UAD
