Georgia Real Estate Commission - The Internet Influence
Keep up to date on the rules in your backyard, before they happen. The Georgia Real Estate Commission is proposing an amendment to rule 520-1-.09 Advertising. It would appear that many of the changes are being instituted to cover any loopholes left open due to internet advertising. Read the amendment today, as there are only a few days left to respond.
Amendments on Appraisals and Valuation Product Requests
Effective January 18, 2014 the Bureau of Consumer Financial Protection amended Regulation B. The final rule revises Regulation B to implement an ECOA (Equal Credit Opportunity Act) amendment concerning appraisals and other valuations that was enacted as part of the Dodd-Frank Act. Prior to the act, applicants would submit written request, within a certain time frame, requesting a copy of the appraisal, per the revisions to Regulation B, creditors are required to provide to applicants free copies of all appraisals and other written valuations developed in connection with an application for a loan to be secured by a first lien on a dwelling. Additinally, creditors are required to notify applicants in writing that copies of appraisals will be provided to them promptly.
Preparing your client for an Appraisal
As a lender, you are responsible for sending a competent professional to appraise your applicants property. VRMC makes that possible with just a few keystrokes. However, the appraisal process can seem a bit overwhelming to some homeowners, but homeowner due diligence can provide for a successful appraisal experience. Lenders should advise the homeowner, that prior to the date of inspection, to document any updates, features or repairs needed to the property, this information can be handed to the appraiser at the time of the inspection. Improvements that typically yield a larger return on value are updating the interior to neutral paint colors, replacing fixtures and modernizing the kitchen and bathroom areas. Appliances, fixtures, switches and plate covers should be uniform i.e. if choosing a stainless steel appliance, then all appliances should be stainless steel. For value, focus on updates that keep your property at the highest value for your community. It can also be a good idea to consult an appraiser to avoid an expensive overimprovement.
Changes for the AMC
Many AMC's are fearful of the joint release letter of March 24, 2014 regarding a proposed rule on Minimum Requirements for Appraisal Management Companies. However, we at VRMC believe all AMC's should be operating at or above these minimum requirements. Nevertheless, as a certified appraiser with almost 15 years of field and review experience, the oversight is welcome. Appraisers for far too long have had to bear the cross alone while taking multiple direction in the collareral valuation department. While other AMC's may be scrambling to implement the changes, the groundwork for VRMC began with these requirements.
Ahead of the Curve
The difference with VRMC is that the change other AMC's are trying to now implement is the VRMC framework. Because VRMC was founded by FNMA forensic review consultants, our minimum standards for review and appraisals are what AMC's are now trying to achieve. The baseline for our company keeps us well ahead of the curve, which keeps us from panicking when new regulations are implemented, because for us at VRMC, it is the standard to provide a quality supported product.
When will it stop
Are you using the same method to get a different result? It seems that's what a lot of lenders were hoping would happen, and why not, afterall, didn't the banks settle all of this with the large dollar settlements? Well, we may not be able to predict when it will stop, but we can say utilizing the same method and seeking a different result may not be the answer.