Legislation

 

AMC Legislation
We are proponents of properly designed legislation of AMC’s promoting fair treatment to appraisers, reasonable dispute resolution policies, and healthy competition between appraisal management companies.

Appraisal management companies are being legislated individually in each state they conduct significant business.  AMC regulations vary from state-to-state and Appraisal Valet is on the forefront of maintaining legislative compliance.  Our chief appraiser and management team have provided significant input to legislative hearings in various states.  While remaining advocates of national AMC legislation to encourage consistent policies, Appraisal Valet respects states with approved legislation and is registered to do business in all necessary states.

Dodd-Frank Act
Dodd-Frank legislation established Appraiser Independence regulations, setting forth clear guidelines that have been fully integrated into Appraisal Valet’s policies & procedures.

Appraiser Engagement
Appraisal Valet is fully responsible for the selection, retention, and compensation of the appraiser.  All members of the lender’s loan production staff are forbidden from communication with the appraiser with regard to loan amount, target value, or loan-to-value ratio, as well as the selection, retention and compensation of the appraiser.  Appraiser selection criteria considers the following attributes:  competency to perform the order, appraiser’s approval status with a specific lender, appraiser availability, appraiser performance score, turn-time requirement, distance from the property, and current capacity.

Appraiser Independence Safeguards

  • Appraisal Valet regularly verifies that all appraisers on its panel are insured and licensed/certified in the applicable state for which they are performing appraisal services.
  • All appraisers are cross-checked with the Appraisal Subcommittee database for active licensing and disciplinary actions.
  • Certification from the appraiser is obtained in each and every report, verifying that no improper influence has been exerted on the appraiser’s independent judgment.
  • Appraisers on our panel are paid the agreed upon fee regardless of the outcome of the valuation.
  • Appraisal Valet does not have their appraisers engage in ‘comp checks’ or any practice of providing an value estimate without completing steps of the appraisal process as governed by USPAP.
  • Appraisal Valet has adopted policies and procedures for the process of formally removing an appraiser from the panel; this process complies with Appraiser Independence regulations.
  • Our quality assurance process includes electronic and manual QC analysis.  This process routinely requires correction or further clarification of their reports.  This is communication process is compliant with non-influence regulations.
  • Appraisal Valet policies and procedures allow for a ‘Dispute Resolution’ process that is to be initiated by the client.  This process allows for client concerns, any report errors, and/or data not considered in the original report to be presented for formal reconsideration.  The dispute resolution process is compliant and is managed by a licensed staff appraiser.

Mandatory Reporting of Appraiser Misconduct
According to the Dodd-Frank Act and associated Appraiser Independence regulations, an appraisal management company who believes that an appraiser has not complied with the Uniform Standards of Professional Appraisal Practice or other ethical or professional requirements set forth by law shall report the appraiser to the appropriate state agency.  This obligation exists only if the noncompliance is likely to significantly affect the property’s value.  In its diligent effort to provide the highest level of quality and remain compliant with all applicable regulations, Appraisal Valet has and will continue to report appraiser misconduct to appropriate state agencies when deemed appropriate.

Customary & Reasonable Fees
Appraisal Valet is paying a fee to the appraiser it considers to be Customary and Reasonable.  Fees are based on fee schedules obtained from appraisers and/or third party surveys with consideration given to complexity, geographic market, type of property, scope of work, appraiser qualifications & experience, appraiser professional record, and volume-based discounts.  Appraisal Valet encourages appraisers to comment to management if they do not agree that fees assigned to specific geographical locations and property types are Customary and Reasonable.  These comments will be collected and considered on a regular basis and should be directed to fees@appraisalvalet.net

Payment of Appraisal Fees
Appraisal Valet is responsible for collecting appraisal fees and providing timely payment of appraisal fees to its panel of appraisers.  At no time shall payment be conditioned upon the opinion, conclusion, or valuation to be reached, on a preliminary value estimate requested from an appraiser, or on the closing of a loan. Appraisers may not be paid directly by any third party.  Paneled appraisers are paid by the 15th of each month for all appraisals completed in an acceptable manner during the prior month.  We are proud of our paneled appraisers and our flawless payment history to appraisers.