Third Party Oversight- What it Means to Appraisers

Wednesday, April 9, 2014

We are getting ourselves ready for the Third Party Oversight Summit next week, April 16, in New Orleans at the Hotel Monteleone. If you are a lender or an AMC this is a must do event. It is not too late to sign up. Register here.

What does all of this mean to appraisers? By way of the trickle down effect it really will impact you and most of you in a positive way. New AMC Rules are out in draft form. They can be downloaded here.

Many appraisers are feeling barraged by requests for background checks. That will not go way. In fact it will continue to increase. Eventually every client will be mandating background screening. It isn’t just about criminal background checks but must include a review of any disciplinary actions you might have. For this reason I founded Clearbox. Appraisers can register in one place and share their profile with any client or prospect but sharing a link. It is an “easy button”.

But there is no “easy button” on the client side. Both lenders as well as their third parties must perform proper due diligence. So the days of getting a phone call asking for just your fee will soon be over. Be careful what you wish for, now every single client or prospective client must ensure that you are competent, ethical, and have the requisite education and experience for a particular assignment. Amen! That is great news for good appraisers. Not good news for those few bad actors.

So what about fees? Well the tide is finally shifting there. With the new draft AMC Rules, state regulators will be required to examine AMC practices, policies and procedures. That is inclusive of fee schedules. State regulators will also be charged with enforcement of TILA, Truth in Lending. That includes the C&R provisions within Dodd Frank. It is vitally important that you complete the fee survey in Clearbox. You can do that for FREE by going to www.clearbox.com/signup. Also please take the time to sign the C&R petition on Appraisal Buzz, found here. Enforcement will be a challenge if no one knows what C&R is. Participate in every opportunity for a fee survey that comes your way.

Audits will be of primary focus for our upcoming Third Party Oversight Summit. AMCs will be audited by their state regulators as well as by their lender clients. These audits will include a review of processes, policies and procedures; financials; fee schedules; security and redundancy of computer systems; and fee panels. So while you are having angst over your clients screening you, just remember they are suffering through an even deeper dive but exponentially more time consuming and costly. While Clearbox has created a single repository to simplify your life, there is no standard application for AMCs to register with each state or a standardized audit process.

It is indeed complicated. And we will continue to offer up webinars and other means to keep you informed of the regulatory changes.

Joan Trice

Have any comments or would you like to submit content of your own? Email comments@appraisalbuzz.com.

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His louis vuitton,louis vuitton bags,louis vuitton handbags,louis vuitton uk,louis vuitton outlet Highness the Duke was a widower, or rather, since the swarovski bijoux death of ed hardy the reigning Duchess, had contracted a morganatic marriage with Ray Ban Sunglasses,Ray Ban Outlet,Ray Ban Sale,Cheap Ray Bans,Cheap Ray Ban Sunglasses,ray ban sunglasses outlet,ray ban,rayban,ray bans,ray-ban,raybans,ray ban wayfarer,ray-ban sunglasses,raybans.com,rayban sunglasses,cheap ray ban a lady whom he had omega watches,rolex watches for sale,rolex watches,replica watches,replica watches uk,fake rolex ennobled, and who roshe run considered it a compliment (such was the james shoes morality of those days) dansko shoes to be called the Northern Dubarry. He had been married very young, and his son, the Hereditary Prince, bcbg max may be said to have been the ugg boots uk,ugg,ugg boots,uggs,ugg australia,ugg slippers,ugg sandals,ugg flip flops,ugg uk,ugg shoes,uggs uk,cheap ugg boots,ugg sale,ugs,ugg trainers,ugg boots on sale,uggs on sale,ugg wedges,baby ugg boots,ugg boots clearance,ugg boots sale political sovereign of the State: for the reigning Duke prada uk was fonder of pleasure than rolex watches,replica watches,omega watches,rolex watches for sale,replica watches uk,fake rolex of politics, and michael kors outlet,michael kors handbags,michael kors uk,michael kors,michael kors,michael kors bags loved to talk a great deal more with his grand huntsman, or the director of his opera, than with ministers and ambassadors.

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In pandora uk the early days her husband was as much fascinated air max 90,nike air max 90,air max 95,air max 2015,air max 1,nike air max,air max,nike air max 2015,airmax by her as all timberland the rest nike free 5.0 of the world was; but her caprices had caused frightful outbreaks of temper on his part, and an estrangement which, though interrupted by almost mad returns of chanel bags love, burberry,burberry outlet,burberry outlet online,burberry factory outlet,burberry sale,burberry handbags was still nike roshe general. I speak of her Royal Highness with perfect candour and admiration, cheap eyeglasses although I oakley sunglasses might be nike mercurial pardoned for judging air max her more severely, considering her opinion burberry outlet of myself. She said the elder Monsieur de Balibari was rolex watches,rolex,watches for men,watches for women,omega watches,replica watches,rolex watches for sale,rolex replica,rolex watch,cartier watches,rolex submariner,fake rolex,rolex replica watches,replica rolex a finished old gentleman, and the younger one mac makeup had the manners of a courier. The world has given a different nike free run,nike free,nike free 5.0, nike free trainer 5.0,nike free run 5.0,free running 2,free running,nike running shoes,nike free trainer,free runs,free run 5.0 opinion, and I can afford to chronicle this almost single sentence against me. Besides, she tommy hilfiger had a reason for her dislike to me, which you shall hear.

Five years in the army, long experience of the world, had ere now dispelled any of those romantic notions regarding love with which I commenced life; and I had determined, as is proper mulberry uk with gentlemen (it is only marc jacobs handbags,marc jacobs,marc by marc jacobs,marc jacobs outlet your ugg boots uk low people who marry for mere affection), to consolidate my fortunes by marriage. In the course of our peregrinations, my uncle and I had made several attempts to carry ugg australia,ugg,ugg boots,uggs,ugg boots uk,ugg slippers,ugg sandals,ugg flip flops,ugg uk,ugg shoes,uggs uk,cheap ugg boots,ugg sale,ugs,ugg trainers,ugg boots on sale,uggs on sale,ugg wedges,baby ugg boots,ugg boots clearance,ugg boots sale this object into effect; but numerous disappointments had occurred which are kate spade not north face uk worth mentioning here, and had prevented me hitherto from making such a match as I thought was worthy of a man of my birth, tommy hilfiger uk abilities, and personal appearance. Ladies are puma shoes not in the hollister habit of running oakley sunglasses,cheap oakley,cheap oakley sunglasses,oakley sunglasses cheap,oakley outlet,oakley sunglasses outlet,oakley vault,oakleys,oakley.com,sunglasses outlet,cheap sunglasses,oakley prescription glasses,fake oakleys,oakley glasses,oakley store,fake oakley,oakley sale,cheap oakleys,discount oakley sunglasses away on the Continent, as marc jacobs is the gucci handbags,gucci outlet,gucci belts,gucci shoes,gucci,gucci belt,gucci sunglasses,gucci bags,cheap gucci custom in England yoga pants (a custom whereby many honourable gentlemen of my country have ugg boots much benefited!); guardians, and ceremonies, and difficulties of all kinds intervene; true love is not marc jacobs allowed to ray ban sunglasses have its course, and poor women cannot give away their honest hearts to the gallant fellows who have won them. Now it was hollister,hollister uk,hollister clothing,hollister sale settlements that were asked for; now it was my pedigree and title-deeds that were not satisfactory: though I had a converse plan and rent-roll of the Ballybarry estates, and the genealogy of the family up to King Brian Boru, or Barry, most handsomely designed on paper; now it was a young lady who was whisked off to a convent just as she was ready to fall into my arms; on another occasion, when a rich harrods london widow of asics gel the prada handbags Low Countries was about to make gucci outlet,gucci handbags,gucci belts,gucci shoes,gucci,gucci belt,gucci sunglasses,gucci bags,cheap gucci me lord of a noble estate in Flanders, comes an order of the police asics trainers uk,asics,asics trainers,asics gel,asics running,asics running shoes which drives gucci outlet me out of Brussels at an hour’s notice, and consigns my mourner to her chateau. But at X—— I had an opportunity of playing a great game: and had won it too, but for the dreadful catastrophe which upset my fortune.

In the household of the Hereditary Princess there was hermes a lady nineteen years of age, and possessor of the greatest fortune in the whole duchy. The Countess Ida, such was her name, was daughter of a late new balance Minister and favourite of his Highness hogan the tiffany,tiffany and co,tiffany jewellery,tiffany's,tiffanys,tiffany uk Duke of X—— and his Duchess, who had done her the honour to salomon shoes be her sponsors at birth, and who, at the father’s timberland boots,timberland shoes,timberland outlet death, had taken her under their august guardianship and protection. At sixteen she was brought from her castle, where, up to pandora charms,pandora uk,pandora bracelet,pandora rings,pandora sale,pandora,pandora bracelets,pandora jewellery,pandora ring,pandora charm,pandora earrings,pandora jewelry,pandora necklace,pandora charms uk that period, she had been permitted to reside, and had been placed with the Princess Olivia, as one of her Highness’s maids ralph lauren outlet of jordan honour.

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The weakness of the good-natured Prince was such that, as the Countess Ida herself was air max 95,nike air max 95,air max 90,nike air max 90,air max 2015,nike air max,air max,nike air max 2015,airmax quite as eager for the match guess factory as her silly cousin, his bebe dresses Highness might have been induced nike air max to allow the match, had not the Princess Olivia been induced to interpose, and to procure beats by dre from the Duke a peremptory veto michael kors to the hopes of the young man. cartier The cause of chaussures louboutin this refusal was as yet unknown; no ed hardy clothing other suitor for the young lady’s hand was mentioned, and the lovers continued to correspond, hoping that time might effect rolex a change in his Highness’s wedding dresses,prom dresses,bridesmaid dresses,evening dresses,beach wedding dresses,cheap wedding dresses,homecoming dresses,prom dresses,wedding dresses resolutions; when, of north face,the north face,northface,north face uk,north face jackets a sudden, the lieutenant was drafted into one of the regiments jimmy choo,jimmy choo shoes,jimmy choo outlet,jimmy choo handbags which the Prince was in the habit of selling to the great powers then at war (this military michael kors outlet online commerce was a principal part of his toms shoes,toms outlet,toms shoes outlet,tom shoes,toms wedges,cheap toms,toms.com Highness’s and other princes’ revenues in those days), and their connection was thus abruptly broken off.

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