Sunday, January 31, 2010

TAVMA Blog - 10 Reasons for Federal Regulation of AMCs



Jeff Shurman, over at the TAVMA Blog, as recently submitted a post - Ten Reasons Why Federal AMC Oversight is the Better Solution. Please take a look when you have a chance. Here's his list:

  1. Compel the federal regulator to create a uniform set of standards for AMCs, which may include or build upon TAVMA’s own Standards of Good Practice in Appraisal Management
  2. Compel AMCs to improve quality as needed to meet the agency’s rules and regulations;
  3. Flag educational and compliance gaps in AMCs’ systems that they can duly address;
  4. Encourage AMCs to invest in IT to meet reporting and compliance rules (compliance, record-retention, performance report generation, etc.);
  5. Provide compliant AMCs with a competitive advantage over those that lag in the compliance area;
  6. Put AMCs – which at the core act as agents of the lender conducting functions that the lender would otherwise do and be responsible for – under the regulatory auspices of the same entity tasked with overseeing, auditing, and supervising the mortgage lending industry;
  7. Ensure compliance of AMC product development efforts to consistent and reasoned standards and guidelines; regulatory clarity leads to innovation;
  8. Provide mortgage lenders a meaningful set of standards against which to assess current and potential AMC partners;
  9. Level the competitive field while weeding out bad actors; and
  10. Eliminate the oft-cited objection that AMCs are unregulated.

Interesting list. Would anyone care to address these one-by-one?

Appraiser Active wonders why TAVMA and AMCs are encouraging Federal Regulation now. It's also interesting, given the increasing number of AMCs being created by unsavory individuals with regulatory agency disciplinary history, that protection of the public does not make the list.

Maybe if the Federal government had not demonstrated such an inability to regulate financial institutions and Government Sponsored Enterprises, we would have a bit more enthusiasm for the TAVMA point of view.

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