Chapter
BANKING AGENCY AND CFPB RULEMAKING
October 2010 Federal Reserve TILA Rule
December 2010 Financial Institution Letter (FIL)
July 2011 FHA Appraiser Roster Rule
Chapter 2 RESIDENTIAL APPRAISALS: OPPORTUNITIES TO ENHANCE OVERSIGHT OF AN EVOLVING INDUSTRY
Composition of the Mortgage Market and Lending Channels
Appraisals and other Valuation Methods
Federal Oversight of Appraisals
Consumer Protection Statutes Relating to Appraisals
THE WIDESPREAD USE OF APPRAISALS AND THE SALES COMPARISON APPROACH REFLECT THEIR RELATIVE ADVANTAGES FOR VALUATIONS IN MORTGAGE ORIGINATIONS
Available Data Indicate That Appraisals Are the Most Commonly Used Valuation Method for Mortgage Originations
Valuation Policies and Practices Generally Reflect the Advantages and Disadvantages of Different Methods
The Sales Comparison Approach Is Required in Nearly All Appraisals Because It Is Considered Reliable in Most Situations
RECENT POLICY CHANGES MAY AFFECT CONSUMER COSTS FOR APPRAISALS, WHILE OTHER POLICY CHANGES HAVE ENHANCED DISCLOSURES TO CONSUMERS
Consumer Costs for Appraisals Vary by Geographic Location, Appraisal Type, and Property Complexity
How the New Requirement That Appraisers be Paid Customary and Reasonable Fees Will Affect Consumer Costs Is Unknown
Policy Changes Limit Costs to Consumers Relative to Disclosed Cost Estimates and Require That the Valuation Report be Disclosed to Consumers Prior to Closing
CONFLICT-OF-INTEREST POLICIES HAVE CHANGED APPRAISER SELECTION PROCESSES, WITH IMPLICATIONS FOR APPRAISAL OVERSIGHT
Recent Policies Address Conflicts of Interest by Enhancing Appraiser Independence Requirements
A Number of Factors, Including HVCC, Increased the Use of Appraisal Management Companies and Changed How other Industry Participants Operate
Greater Use of Appraisal Management Companies Highlights Potential Shortcomings in Existing Oversight and Has Raised Questions about Appraisal Quality
RECOMMENDATION FOR EXECUTIVE ACTION
AGENCY COMMENTS AND OUR EVALUATION
APPENDIX I: OBJECTIVES, SCOPE, AND METHODOLOGY
Chapter 3 REAL ESTATE APPRAISALS: APPRAISAL SUBCOMMITTEE NEEDS TO IMPROVE MONITORING PROCEDURES
SEVERAL WEAKNESSES HAVE POTENTIALLY LIMITED ASC’S EFFECTIVENESS IN PERFORMING ITS TITLE XI FUNCTIONS
ASC Has Improved State Compliance Reviews, but Its Enforcement Tools and Reporting Procedures Have Been Limited
ASC Has Not Developed Policies and Procedures for Monitoring the Appraisal Requirements of the Federal Financial Institutions Regulators
ASC Monitors the Appraisal Foundation but Has No Written Policies for Determining Whether the Foundation’s Grant Activities Are Title XI-Related
ASC Maintains a National Registry That Includes Data on State Disciplinary Actions
DODD-FRANK ACT PROVIDES ASC NEW AUTHORITIES AND PRESENTS IMPLEMENTATION CHALLENGES
The Dodd-Frank Act Expands ASC’s Role and Provides New Tools to Oversee State Appraiser Regulatory Agencies
Grants to State Regulatory Agencies
Rulemaking Authority and Enforcement Tools
ASC Faces Resource Challenges and Is Developing a Strategic Plan
MOST RECENT MORTGAGES WERE BELOW THE THRESHOLD FOR APPRAISAL EXEMPTION, AND STAKEHOLDER VIEWS ON THE THRESHOLD VARY
Appraisal Industry Stakeholders Have Differing Views on Revising the Exemption Thresholds
RECOMMENDATIONS FOR EXECUTIVE ACTION
AGENCY COMMENTS AND OUR EVALUATION
APPENDIX I. OBJECTIVES, SCOPE, AND METHODOLOGY
ASC’s Title XI Functions Prior to the Dodd-Frank Act
Implementation of Dodd-Frank Act Provisions
Dollar-Based Appraisal Exemption Thresholds
National Appraisal Repository
APPENDIX II. DATA ON THE NUMBER OF APPRAISER CREDENTIALS AND STATE ENFORCEMENT ACTIONS AGAINST APPRAISERS
APPENDIX III. POTENTIAL BENEFITS AND CHALLENGES OF A NATIONAL APPRAISAL REPOSITORY FOR ASC
APPENDIX IV. STATUS OF ASC TASKS STEMMING FROM THE DODD-FRANK ACT
Real Estate Appraisals: Oversight and Improvement Opportunities
( Economic Issues, Problems and Perspectives )
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