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.
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