News & EventsIndustry Compliance Letter
2011' has been a challenging year for the industry due to a large number of legislative acts that have been enacted throughout the country, greatly affecting the appraisal process. 2012' is slated to be no different, and just as challenging with an implementation forecast of Appraisal Management Company Registration Acts ["AMC"] in several states. Some of these Acts include procedural or technical requirements that AMC's and its panel members must adhere to. There are a handful of states currently in the final rulemaking stage, resulting in immanent policy changes.
Nationally, the HVCC sunset in 2010 and the Dodd-Frank Wall Street Reform and Consumer Protection Act is now the law of the land under the Consumer Financial Protection Bureau ["CFPB"]. It is imperative to understand the new Reg Z requirements in this Act, as well as, directives issued by the CFPB.
On the compliance front, HUD has issued its long-awaited Mortgagee Letter outlining their adoption of the Uniform Appraisal Dataset ["UAD"]. HUD states that the UAD is the result of collaborative efforts between the GSE's (Fannie Mae and Freddie Mac), at the direction of the Federal Housing Finance Agency. The UAD is part of the Uniform Mortgage Data Program, which includes the Uniform Collateral Data Portal and the Uniform Loan Delivery Dataset.
On the delivery end, 2012 secondary considerations include adherence to state/federal and conduit compliance requirements. The aforementioned HUD announcement (which includes FHA), had not been made public until Mortgagee Letter 2011-30 was published on August 22nd, 2011, and details the implementation of the UAD. The announcement states that "FHA will be adopting the UAD for all case numbers assigned on or after January 1, 2012 and for all HUD REO appraisals and Pre-Foreclosure Sale (PFS) appraisals with an effective date on or after January 1, 2012."
In today's climate, it is prudent to work with established firms that are familiar with these national protocols. Finding the right AMC to service your needs is almost as intensive as keeping track of all new regulations. Prudent oversight strategy is the key for success in 2012, as failure to keep track of new laws and delivery requirements could adversely impact your firm.
If you find yourself in the need of legislative analytics or an AMC that can provide the type of service needed in today’s market, feel free to reach out to the Sales and Marketing team at (949) 862-1425 or via email at marketing@fasinc.com.
