Bank Compliance

If your institution has any of the following questions or issues, Richard can help:

1. Who Can Perform Appraisal Reviews?
2. Do the “reviewers” have to be certified?
3. What are bank auditors and regulators looking for when they walk into your institution (or AMC)?
4. Internal appraisal division or external AMC – What are other lenders experiencing?
5. Which new AMC laws and regulations will impact my institution?
6. Is your institution experiencing appraisal and/or AMC compliance issues?
7. Mandatory reporting of USPAP violations – When and where do we report?
8. Appraiser Independence – Compliance issues and solutions;
9. Dodd/Frank Acts’ additional legal burdens on lenders, AMCs, and appraisers.

Richard helped write many of the laws that impact appraisers and lenders. He has an understanding of the “Policies and Procedures” lenders must deploy when dealing with appraisals, evaluations and AMCs. He has a strong familiarity with: The Interagency Appraisal and Evaluation Guidelines (1992 through 2013); Management Considerations Regarding Third-Party Relationships (AMCs); Fannie Mae/Freddie Mac Appraisal Requirements; Appraiser Independence Requirements (AIR); Financial Institutions Reform, Recovery and Enforcement Act of 1989 (FIRREA); Housing & Economic Recover Act of 2008 (SAFE Act) Fraud Enforcement and Recovery Act of 2009’; TITLE XIV—Mortgage Reform and Anti-Predatory Lending Act – The “Dodd/Frank Act”…all 2,319 pages.

1. Real estate and mortgage fraud

2. Appraisal requirements

3. AMC interactions

4. Licensing & registration of loan originators

Richard has created classes dealing with the following issues:

• Interagency Appraisal and Evaluation Guidelines
• Appraisal Compliance Issues – Auditors and Lawsuits
• AMCs – How They Operate and Impact Banks
• The Requirements Third-Party Relationships (AMC Liability)
• Overview of Lawsuits Involving AMCs and Lenders
• New AMC Licensing Laws and Regulations
• Appraisal Review and Underwriting – New Laws and Requirements
• Foreclosure, Short Sale and Loan Modification Fraud
• How to Identify and Prevent Real Estate and Mortgage Fraud

Legislation/Regulation

• Helped write the draft version of the federal Secure and Fair Enforcement for Mortgage Licensing Act (SAFE ACT). (12 USC/Chapter 51);
• One of the authors of Washington State’s Mortgage Brokerage Practices Act. (RCW 19.140);
• One of the authors of Washington State’s Appraisal Management Company Registration and Regulation Act. (RCW 18.310) Versions were adapted in 4 additional states. Sections were incorporated into federal laws;
• Testified before Washington State’s Senate and House concerning appraisal, AMC and, the mortgage industry 1992, 94, 97, 2005, 08, 10;
• Advisory panel, State of Washington Mortgage Broker’s Commission, 1992-1994 and 2004;
• Advisory panel, State of Washington Appraisal Commission, 2008-2012;
• AMC Commission (tasked with writing AMC laws and regulations) 2009-2011.

(Training for state and federal law enforcement and prosecutorial agencies available upon request)

Instruction – Live Richard has taught live classes to members of the following associations and agencies:

• Federal Deposit Insurance Corporation (FDIC)
• Office of the Comptroller of the Currency (OCC)
• National Association State Credit Union Supervisors (NASCUS)
• National Credit Union Administration (NCUA)
• Credit Union National Association (CUNA)
• Association of Credit Union Internal Auditors (ACUIA)
• Association of Credit Union Internal Auditors (ACUIA)
• Department of Financial Institutions (AZ, WA, OR, IN, NC, FL, NY)
• Office of the Attorney General (AZ, OR, WA, IN)
• American Association of Residential Mortgage Regulators (AARMR)
• Association of Appraiser Regulatory Officials (AARO)

Instruction – Web In addition to the above live or in office training, Richard has provided web based training to the following attendees:

• Governance and compliance officers working for more than 300 lenders (federal banks, state and community banks, credit unions and private lenders)
• Individuals working within every major federal banking agency including the Department of the Treasury, Office of the Comptroller of the Currency, Federal Deposit Insurance Corporation
• Credit union supervisors. managers and auditors

1. Appraisals: What you need to know now;
2. Understanding Commercial Real Estate Appraisals;
3. Mortgage Loan Scams, When Real Estate Isn’t Real;
4. Appraisal Process – New Requirements / HVCC for banks;
5. Appraisals: New rules, new forms, new procedures;
6. Understanding Appraisal Management Companies (AMCs) and Other Third-Party Relationships;
7. Required Licensing or Registration of Loan Originators;
8. Identifying and Preventing Mortgage Loan Fraud;
9. Appraisal Review: Saving Time and Costs;
10. Get Ready for the Implementation of the SAFE Act;
11. SAFE Act Implementation Issues, A Practical Guide;
12. Fannie Mae & Freddie Mac’s Appraisal Requirements;
13. SAFE Act Implementation Issues, A Practical Guide #2;
14. Appraisals and AMCs – The Dodd-Frank Act Creates a New Compliance Reality;
15. New Interagency Appraisal and Evaluation Guidelines;
16. Appraiser Independence and Mandatory Reporting;

Class Descriptions and CD-ROMs – BankersOnline: Bank Compliance Training