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.

Sunday, January 17, 2010

Larry Holzer - New Appraisal Managment Company

Back in May, 2009, Appraiser Active posted about the need to regulate Appraisal Management Companies. The failure to regulate Appraisal Management Companies provides way too many opportunities for abuse of the system, scant protection for property owners, borrowers and lenders, and limited means to assure wrongdoers meet justice. The post included a link to an article in by Susan Taylor Martin, Senior Correspondent for the St. Petersburg Times.

At that time, Larry Holzer was operating an Appraisal Management Company; Global Appraisal Solutions. (Note: link is to the wayback machine). Through the grapevine, we've heard that Global Appraisal Solutions is no longer operating. We've also heard of a few independent contractor appraisers stiffed by his firm as it took the dive, similar to what happened with Security One Valuation Services, LLC.

There were some warning signs. Appraisers on the Global Appraisal Solutions panel received this email:

From: []

Sent: Tuesday, October 06, 2009 12:50 PM

Subject: Important Update: Global Appraisal Solutions

October 6, 2009
Dear Appraisers,

Good afternoon.

Approximately five days ago, I wrote to advise you that a dispute has arisen between Global Appraisal Solutions and one of the lenders that the company serves.

The dispute involves various areas of alleged lender misconduct, including, but not limited to a large outstanding balance for completed appraisals as well as lender practices that Global alleges violate banking regulations.

It is important that during this time, we remind you that any outstanding appraisal that was requested by you from Global Appraisal Solutions that you do the following things to help us to quickly resolve the dispute:

1. Complete the appraisals with professionalism and speed.
2. Ship the appraisals and the conditions ONLY to your client: Global Appraisal Solutions
2. Report by email to Global Appraisal Solutions any attempt by the lender to seek the appraisals or conditions from you directly, or any other thing that the lender may do or attempt to do, that would otherwise compel you to violate USPAP, HVCC, or state law.

Global is communicating with the appropriate parties and we do anticipate settling this matter in the coming days.

Thank you.


Larry Holzer
President, Global Appraisal Solutions, LLC.

If having his State Certified Credential revoked by the Florida Real Estate Appraisal Board will not keep him from opening and operating an Appraisal Management Company, why should folding an Appraisal Management Company keep him from opening another?


From the site (I'm tempted to tag this 'sarcasm on').

Appraisal Mediation Solutions is one of the most trusted providers of real estate valuations in the Nation. Our philosophy is to provide fast and accurate real estate valuations to assist our clients in making informed real estate decisions. Our reports are prepared with the precision that the industry demands with all major property types included.
The filing with the Florida Division of Corporations indicates the principal office of the Limited Liability Company is:

140 Island Way
Clearwater, FL 33767

For those lenders, mortgage bankers, mortgage brokers and appraisers interested in doing business with Appraisal Mediation Solutions, LLC, you might want to research the palatial principal office. Just in case you are interested, Appraiser Active has done this already. Take a LOOK at the business at that address.

If you're an appraiser, and interested, he's also hiring. Let me know if the link goes dead. I've got a pdf of the page to post if necessary.

More than likely, there are thousands of businesses operating with a UPS box as their principal office, but I'm just sayin'.......

It looks like fly-by-night Appraisal Management Companies will be all the rage in the 2010's. Be careful of the companies you work with.

Thursday, January 14, 2010

Security One Valuation Services - January, 2010 Update

It's been over two months since we last heard from Todd Barfield about the checks issued by Security One Valuation Services, LLC. Appraiser Active has provided updates on the Security One debacle in November, 2009, October, 2009, September 23, 2009, September 18, 2009, and provided two posts at the start of the fiasco; August 11, 2009 and August 5, 2009.

For a while, it seemed like Todd was interested in working things out with the legions of appraisers stiffed with rubber checks, and anxious to get the word out about his efforts to make things right. In the interest of helping him get the word out, messages were sent to him over the past couple of weeks. Instead of a response, I've been listening to the chirping of crickets.

Appraisers holding dishonored Security One checks email me every week. Comments about the Security One problem are posted regularly. It's not unusual for me to get telephone calls from all over the country from appraisers hungry for information and anxious to get their hard-earned money.

As much as I'm interested in helping, there's little I can do but write about it. I'm not in the collection business. I never accepted an assignment from Security One. In fact, Gregoire & Gregoire, Inc. DOES NOT accept appraisal assignments from Appraisal Management Companies. However, someone is doing something other than writing about the pain and hardship caused by Security One Valuations Services, LLC.

Just this week I heard from a Napa, California appraiser. He is holding a fistful of Security One dishonored checks and is steaming mad. After pursuing a number of options, he talked with his local law enforcement agency; the Napa County, California Sheriff's Office. As a result, the Sheriff's Office is interested in going after Security One.

We're not sure how this will work out, but the Napa County Sheriff's Office asks that appraisers owed money by Security One, and holding dishonored checks send their names, contact information with company name, address and amount owed to:

Appraiser Active is making no guarantees. We're not holding any bad checks and have not talked with the addressee. Instead, we're merely passing along some information. Let me know what you learn.