|
CoAA - AMC Talking Points:
The purpose of this bill is not only to regulate Appraisal Management Companies, but to protect the public. To accomplish this, the bill requires the following:
registration and background checks on companies (any person, corporation, or other business) operating in Arizona engaging in business as an Appraisal Management Co. regardless of the name
AMC may not be owned by a person or have any principal of the company who has had a license or certification refused, denied, revoked, surrendered, etc. by any state
AMC must identify a "controlling person" responsible for the operation
AMC companies must comply with the HVCC rules and have a system in place to make sure their approved appraisers are licensed or certified and in good standing
AMC will pay a registration fee set by the AZ Appraisal Board
AMC will show proof of a surety bond of $20,000
there will be an annual renewal and compliance report
verify the fee paid to the appraiser is disclosed in the certification of the appraisal report
appraisers are to be paid their fee within 45 days
no coercion, undue influence, pre-determined values, threats, etc. are allowed
a process will be established to handle complaints about an AMC
AMC employees that order appraisals are to be educated, and Review Appraisers to be licensed in Arizona
Benefits of the AMC Bill to Realtors:
AMC bill will rid the State of unethical and incompetent AMC companies
It will give the Realtors a place to file complaints regarding HVCC violations, incompetent appraiser usage, unethical AMC practices
Will require transparency of appraisal fees and AMC fees
Will require AMC employees to be educated on appraiser Standards and Ethics, Scope of Appraisal and appraiser competency
AAR can show the Realtors in Arizona that they are effectively helping to change some of the recent failings of HVCC and the new ordering system of appraisals
CoAA – AMC Talking Points
Benefits of the AMC Bill to Banks:
- Banks need to comply with HVCC and the AMCs are not doing this, or not doing it well. State regulation will be the check system to make sure ALL the AMCs are complying with HVCC. This will guarantee that the competitors of the large banks are playing by the same rules.
- Banks are losing business via poor AMC management, which is looking for the quickest and cheapest appraisals. This causes loan losses for the banks.
- Bank reputations are being adversely affected by poorly operated AMCs that have people who are uneducated in the appraisal process, assigning orders to only appraisers on their approved list. This results in orders for complex appraisals going to unqualified appraisers, etc. The AMC law will require education for employees and has a provision for hiring competent appraisers.
- Banks should appreciate the background check system and owner disclosure required by state registration laws
- Banks can also file grievances against the AMCs, should the need arise, via the accountability provisions
|