AI’s Effort to Eliminate the ASC!

Michael Ford

Michael Ford

General Certified Real Estate Appraiser at Michael F. Ford Appraisal
Over 28 years appraising all property types and interests, in Southern California real estate. VP/Chairman National Appraiser Peer Review Committee, American Guild of Appraisers, #44OPEIU/AFL-CIO. - Michael Ford on e-AppraisersDirectory
Michael Ford

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Eliminate the Appraisal Subcommittee too! Appraisal Institute Effort to Eliminate the ASC

Refocused effort to eliminate the ASC…

Why?

It’s now much more than rumor.

There is a concerted effort to eliminate not just the Appraisal Practices Board (APB) which was the Appraisal Institute’s original target, but now a refocused effort to eliminate the Appraisal Subcommittee (ASC) itself!

Think about that folks. What started as a partisan effort to lay ground work for the eventual elimination of Dodd-Frank has quickly morphed into a behind the scenes opportunistic all out push to eliminate the ASC too!

It’s no secret among regular Appraisal Institute (AI) members or non AI appraisers that have listened to AI paid lobbyist’s testimony at public The Appraisal Foundation (TAF) meetings that they wanted the Appraisal Practices Board eliminated. Maybe AI fears they may provide better education…and for free!

These are the same people (AI lobbyists) that have repeatedly tried to claim that they speak for “all appraisers’ interests, even to the exclusion of their own interests (Redondo Beach TAF Meeting).”

According to many current AI members, they no longer listen to their own members, let alone unaffiliated appraisers or those that belong to other professional organizations.

…explore the ramifications if they successfully cause actions to eliminate the ASCAnyway, my objective is not to heap well-earned criticism on the AI, but rather to explore the ramifications if they successfully cause actions to eliminate the ASC, or usurp the rights of all other appraisers in America and/or to create an educational course monopoly-with themselves as the sole beneficiary.

Let’s assume Congress does decide to repeal Dodd-Frank. We already know they don’t like the provisions that place undue hardships on financial institutions, or the creation of the megalithic Consumer Financial Protection Bureau (CFPB). As far as appraisers are concerned, there is little effective benefit to appraisers in Dodd-Frank. Nothing that couldn’t be done better-differently. The real alarm and concern is over HOW Dodd-Frank gets repealed. Do they stop with Dodd-Frank or do they accede to AI special interests to the detriment of ALL appraisers, taxpayers and consumers?

The ASC was created at the direction of Congress in the Financial Institutions Reform, Recovery, and Enforcement Act (FIRREA) of 1989. To date it has worked reasonably well despite the attacks against ASC by House Finance Subcommittee Members at the recent webinar broadcast hearings. As required by law, ASC conducts biennial audits of states appraisal licensing and regulators. The Committee member (Chair?) asked how many debarments had taken place in 25 years. While it sounded logical on the surface, it was a Catch-22 type question. If the ASC HAD debarred any state (decertification of their process) it would have resulted in

  1. ALL appraisers in that state becoming instantly ineligible to perform appraisals in federally related transactions.
  2. It would also have eliminated federally related transactions in those states.
  3. It would also have resulted in an overnight uproar involving elected legislators from BOTH House & Senate. As banks, lenders, state legislators and even those sanctioned regulators sought to reverse the decertification; or at worst have them modified into only Notices or Warnings.

Last year the ASC audited 29 state programs. Of those, six (20.7%) were cited as needing to improve – that’s the administrative regulatory step before decertification. Contrary to partisan comments, the ASC HAS performed its duties as intended by Congress and done so responsibly.

Are there areas that could be improved? Certainly. I can think of a few states that will not likely change bad/abusive practices with anything short of imminent threat of decertification. California and Illinois come to mind almost immediately. Maryland and Oregon could also be contenders. Please note I said threat rather than actual decertification. Of course Illinois is where the AI is home based and perhaps their influence and manipulation accounts for perceived problems there too.

In order to dismantle the ASC Congress would have to gut FIRREA 1989 which created it!

I know my party is seen as a party in favor of minimal regulations, but NO ONE in the party would be foolish enough to suggest we revert to the days of Lincoln Savings and Loan, or Keating!

Dodd Frank only provided window dressing reforms. Lofty ideals with little effective enforceability. It was onerous and cumbersome. It tried to do too much at once in too many unrelated areas. Altruistic, but lacking focus.

Dodd-Frank’s repeal need not be catastrophic. FIRREA however is another matter. Its repeal, or further watering down, or more special carve outs to accommodate the self-serving interests of only the AI will virtually guarantee new national economic disaster and across the board financial institution scandals.

NO responsible businessman wants absence of all regulation. We want prudent checks and balances and a level playing field. Prudent checks and balances are not oppressive or bad for business. On the contrary, they assure continued economic stability, health and growth in all sectors. Wall Street LIKES stability and responsible growth!

I took my first AI courses in 1986 at BIOLA College (Bible Institute of Los Angeles). There was no question after that course as to what ethical behavior was and what was not. But then again it was taught by MAI’s who took their responsibility AND Standards of Professional Practice seriously.

What has happened to the AI, or its members that makes their current leadership suddenly decide after thirty one years that their designated members need a new, special ethics course now? Have they been chipping away at generally accepted sound appraisal practices for so long that they have forgotten the fundamentals of integrity and ethical behavior that used to be their cornerstone and main claim to fame? Too many years of looking the other way when ‘special’ members were involved? Maybe that’s what happens when you try to make the CORE PRINCIPLES fit business models instead of adopting business models in accordance with core principles.
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Perhaps leadership looked in an ‘ethics mirror’ and didn’t like the view.

Have basic concepts of right and wrong or common sense and professional integrity become too confusing after over 25 years of special carve outs?

The MAI’s, SRPA’s and SRA’s that I personally know have no trouble knowing or determining what is ethical and what is not. THEY learned it as children. AI (or AIREA as they used to be known) merely immortalized it (ethics) in written policies and practices…and yes documented principles. Principles AI leadership doesn’t appear to think much of anymore.

I urge ALL Members of Congress to reject this AI special interest push. Correct Dodd-Frank or repeal it as you believe best but don’t allow its desired repeal to be used as a cudgel against what is right in our regulatory system.

For the record Dodd-Frank has NEVER been an impediment to appraisals in America. There is no shortage of appraisers and Dodd-Frank is not a bar to new entries in the appraisal profession.

AI does NOT speak for all appraisal interests any more than I can claim to as a representative of the American Guild of Appraisers. There are over a dozen respected OTHER professional peers groups PLUS over 22 state coalitions that can speak for themselves IF invited to the table to do so. There are also nearly a dozen chimera “appraiser” groups formed by AMCs, and their sponsors. There are dozens of State Approved Real Estate Appraiser CE courses in America that are more cost competitive and convenient for appraisers than AI courses. The National Association of Realtors also deserves a seat at the table.

Let’s hear from ALL affected parties BEFORE we pass new laws or repeal existing ones.

Image credit flickr - Irish Defence Forces
Michael Ford

Michael Ford

Over 28 years appraising all property types and interests, in Southern California real estate. VP/Chairman National Appraiser Peer Review Committee, American Guild of Appraisers, #44OPEIU/AFL-CIO. – Michael Ford on e-AppraisersDirectory

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38 Responses

  1. Diana N. says:

    I remember 30+ years ago when a bank wouldn’t use an appraiser unless you had an MAI designation. Anybody else been around as long as I have that remembers that, or was it only in CT.?

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    • Retired Appraiser Retired Appraiser says:

      Now you only need a large bank account and a membership in the same country club.  My how things have changed.

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  2. Retired Appraiser Retired Appraiser says:

    Or if you are really really lucky…they will eliminate each other!

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  3. Charles Baker says:

    I’m not aware of any effort to eliminate the ASC. As an SRA member, I’ve attended LDAC twice. We’ve merely talked with our representatives to consider holding hearings on reforming appraisal regulation. Our main issues have been licensing portability and resolving conflicts with respect to mandatory vs non-mandatory states. In other words, some states require USPAP compliance for any and all appraisal practice whether for an FRT or not, while other states allow appraisers to opt-out.    

    I do agree with some that the ASC has exceeded its mandate when TAF / AQB began offering various education programs beyond USPAP. So, not only are they in the business of regulating existing course providers, they are directly competing with them. AI spoke up about this when they were still a sponsoring organization and TAF slapped them down.

    This blog is just hyperbole. It isn’t quoting any authoritative source. Rather the author is taking a giant leap – saying on one hand, “paid lobbyists” are testifying in public their desire to see the APB eliminated . . . to saying in bold, “. . . now a refocused effort to eliminate the Appraisal Subcommittee (ASC) itself.”  What follows adds nothing to the original charge.

    The APB recently took it upon itself to suspend its activities. So, who’s wagging the dog here?

    If there is such an effort to eliminate the ASC, this article does a poor job proving it.

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    • Hi Charles, the AI has not made a public announcement stating they seek to eliminate the ASC. THAT comment came from a source who met with House Members and others who advised him that was the intent. He’s indicated he’ll send me names of the Congress Members and their contact information sometime next week. (IF you’ve ever tried to reach a Congress Member, you’ll know their official emails tend to screen out people outside of their district’s zip codes).

      I also heard from the  AI Lobbyists own mouth at the Redondo TAF meeting referenced in the article about AI’s past claims to speak for all of us. He even got up a second time to tell all attendees that he refutes MY objection about their NOT speaking for all appraisers. His claim was that AI even sets aside its own interests in order to promote what’s best for the profession. THAT is a matter of public record.

      During the recent webinar-broadcast meeting of the House Sub Committee the AI lobbyist directly testified that he believed the APB was an unauthorized Board that should be disbanded.

      He also promoted or supported the concept of a single NMLS style national license; and claimed there is a nationwide appraisal shortage.

      Charles, not one of his suggestions was ‘for the benefit’ of the appraisal profession. Each was geared specifically to benefit the AI and primarily it’s MAI’s. He never did address how the issue of geographic competency would be dealt with by these proposed cross state line traveling appraisers. We are left to assume they will all act honorably and professionally and build in extra time to acquire geographic competency when they travel across state lines for work.

      Also not addressed is how they will learn ALL the visited states individual real estate, environmental, special land use, or other restrictive regulations and market nuances. That’s not to say these things can’t be done, but given long standing track records of appraisers (yes, EVEN some MAI’s) side stepping or only complying with what they absolutely have to; coupled with clients ever increasing demands for faster and cheaper products forgive me if I’m skeptical.

      As for objections about TAF offering unauthorized competitive courses I’ve never seen any or heard of any being advertised for the general public (Yes, they DO offer and pay for regulators courses). Despite that IF they wanted to compete with AI’s courses, their bylaws certainly permit it.

      Their 2012 strategic plan included proposals to develop WHOLESALE courses based on input from their Advisory Council for sale to retail educational course providers. Readers can check the details here. They weren’t seeking to compete, but rather to assure uniformity of material, consistent with standards; uninfluenced by bias inherent in commercial course provider materials.

      Charles, the hyperbole originates when an AI lobbyist gets up to speak. Not when those of us who learn of pending adverse, anti appraiser interest legislation attempt to cut it off before it gets a real foothold…like HVCC did.

      In any event thank you for sharing your views. Readers should have ALL views available in order to make their own judgments. Please don’t hesitate to contact me at my email address or through the Appraisers Guild at any time. (mf)

      For my part I will post source and or reference contact data as soon as it becomes available.

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      • Charles Baker says:

        Thank you Mike. I appreciate your response.

        I’ve visited Washington DC twice in the past two years on behalf of the AI.  We visited our respective House representatives and Senators.  I personally met Diane Feinstein and met her staff twice, along with Boxer’s staff. I’ve also visited House members Issa, Rohrabacher and Chu. I do realize the difficulty dealing with House members outside your home district. No mystery there. That’s the way it’s always been. btw – I already have contact information for all 535 House members and 100 Senators.

        You referred to a single unnamed source who met with House members. Was this person an AI member?

        Keep in mind, members of Congress are lobbied every day of the week. At our meeting with Feinstein’s office in ’15, a woman seated next to us in the waiting room was going to lobby for marijuana legalization.

        My visits to DC were on behalf of the entire appraiser population and AI secondarily. I was never told to lobby for the elimination of the ASC.  That being said Dodd-Frank reform was discussed.  Representative Hensarling is pushing legislating to do just that.  He gave a presentation to AI members at an LDAC meeting.

        The fact that an AI lobbyist testified that the APB should be disbanded is not somehow inappropriate or nefarious.  If you watched the testimony from all participants, including Joan Trice, there was much disagreement on the matter of TAF and appraisal regulation in general.  It was a good exchange of ideas.  In fact, the APB recently suspended its OWN activities, no doubt unprompted by this AI lobbyist.

        With respect to licensing portability, there are appraisers who practice in more than one state now.  A colleague of mine must renew his licenses in over 15 states every cycle. It’s a huge and unnecessary burden. Geographic competency is enshrined in USPAP and license portability doesn’t diminish that in the slightest.

        With respect to education, the only outside course provider linked-to on the TAF website is McKissock. How is that appropriate? AI and its predecessor organizations have been educating appraisers for 80+ years.

        In my opinion, you are ascribing nefarious motives of the AI based on a single unnamed source, which only serves to cloud a perfectly legitimate debate we should be having about the future of the ASC and our industry.

        Thank you for the opportunity to respond.

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      • Charles Baker says:

        Mike – I’m also going to take umbrage at your suggestion that AI only exists to serve its members.

        I sit on the CA Government Relations Committee and attend two in-person meetings throughout the year, one in Sacramento and one in SoCal to engage with our representative to monitor and introduce legislation impacting our industry.  Two recent bills we introduced and got passed benefitted EVERYONE – AMC licensing and mandatory documentary transfer stamp disclosure.  A lot of hours went into these efforts which were paid for by AI membership dues.

        A little balance would be appreciated.

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        • Mike Ford Mike Ford says:

          Charles, your viewpoint is respected but as for AI’s California activity why is it NO ONE outside of AI or their lobbyists were informed or asked for their input? If you were on the Committee when AB624 was being sneaked (literally) through the legislature why was there no effort to  invite California Appraisers for input or views?

          I certainly hope you are not including AB 624 as one of those two recent bills that benefited “everyone.”

          We’ve been telling AI the same thing for years …”a little balance would be appreciated”

          I’m told by a local AMC that AMC licensing has been the law in California since at least 2010.

          Reporting documentary transfer stamps has been a requirement for all counties in California  since I was first licensed as an agent back in 1971. It was in effect when I was Chief Appraiser at an L.A. based title company  in the early 1990’s; and on the General Plan Advisory Committee in Redondo Beach (same period). It has been a requirement here the entire time I have been an appraiser (from 1986 til now). Working in Pasadena, you should know that.

          Charles, I’m not doubting AI worked to have self interest bills passed in California. What I am skeptical of is that they worked for the passage of anything recently, that benefits anyone other than themselves.

          I keep an open mind. Had you pointed to something that actually happened recently or of benefit to all or even most appraisers, I’d admit it and temper my remark’s or even apologize for any errors inadvertently communicated.

          You have balance. Better than balance, you also have truth submitted for review by our peers and their comments.

          You don’t seriously want to claim sacrifice for AI paying for their own self interest lobbying do you?

          Anyway, I’ll buy you a cup  of coffee and we can politely debate AI’s altruism if you are going to be at Torrance Marriot TAF/BOT meeting tomorrow. If nothing else I can post after that you may be an exception to AI generalities.

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          • Mike Ford, AGA, CA AG, GAA, RAA, Realtor ® Mike Ford, AGA, CA AG, GAA, RAA, Realtor ® says:

            PS I only speak for AGA members and on behalf of OPEIU/AFL-CIO member taxpayers, consumers, retirees and their families and even there; only on appraisal or relevant RE related issues. ANY of those members are always welcome to express opposing views. Several post here too. Sometimes they agree. Other times they do not.

            I do not claim, nor have I ever claimed to speak for “all appraisers“. You see, THAT is something ONLY AI members or their lobbyists do…particularly when no one has notified the rest of America’s appraisers that a conversation is taking place. Charles I cannot believe you just posted that here. Seriously?

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          • Charles Baker says:

            Mike –  I came aboard in 2015 so I wasn’t there during the drafting of AB624 but participated in lots of discussion as it made it’s way through.  It passed out of Sen Appropriations 7-0.  It passed out of Sen Bus Professions & Econ Dev Cmte 6-1.  It passed out of the Assembly 78-0.  It passed out of the Asm Appropriations and Business and Profession Cmt’s 17-0 and 14-0, respectively.  It stalled out when the finance subcommittee scored the cost of enforcement – at a ridiculous figure.  Suddenly, Jim Martin (who is statutorily forbidden from taking a position on any pending legislation) opposed it.

            Currently, there are 15 non-mandatory states in the US.  Once an individual is state licensed or certified, any work or service performed by that person (including nonfederally related real estate appraisals) must be performed in accordance with USPAP, and is subject to regulation and oversight by the state appraiser regulatory agency. Compliance with USPAP is not required by a person who is performing real estate appraisal services but is not a state certified appraiser. There are currently no state alternatives to compliance with USPAP for state certified appraisers that are performing appraisals for non-federally related transactions.

            So, the upshot is . . . state agencies have no oversight for NON-licensed appraisers performing real estate appraisal services.  The point of AB624 was to allow licensed appraisers who perform non-FRT work to use alternative standards AND incentivize non-licensed appraisers to come “into the tent” of state oversight.  That’s it in a nutshell.  There was no mention of AI in the bill. Look it up.

            With respect to AMC licensing.  YES – the AI Government Relations Committee authored and pushed AB-1796 in 2010. I know several on the committee that were instrumental in ushering it through at that time.  Look it up.

            With respect to doc transfer stamps.  The problem for years was that assessors were allowed to stamp the back of the deed thus keeping the price out of the public record.  The bill that changed that was AB-1888, written and ushered through by this committee in 2014.  Again, look it up.

            Bill Text – AB-624 Real estate appraisers: standards of conduct.

            Bill Text – AB-1796 Appraisal management companies.

            Bill Text – AB-1888 Documentary transfer tax: document for recordation: amount of tax due shown on separate paper.

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            • Mike Ford, AGA, CA AG, GAA, RAA, Realtor ® Mike Ford, AGA, CA AG, GAA, RAA, Realtor ® says:

              Ever wonder what a pile of steaming pony loaf looks like after it’s cooled down?

              Congress Hears Appraisal Institute’s Ideas to Modernize Regulation – AI News Releases – News | Appraisal Institute

              Read 4th Paragraph in particular. My question is: If the appraisal regulatory system has remained essentially unchanged since 1989, then how exactly are we being buried under federal (or state) regulations?

              Has it changed, or not? The layering, background checks and other burdens on our profession are originating from lenders, AMCs and FNMA not federal regulators!

              Its just the opposite-LACK of meaningful or effective regulation has allowed the events described to take place.

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              • Charles Baker says:

                With all due respect Mike, I’m not following you at all here.

                Federally charted banks, S&L’s, credit unions, etc. all must follow federal regulations.  The GSE’s are under FHFA oversight.  And six federal financial regulatory agencies issued a final rule in 2015 that implemented the minimum requirements for state registrations and supervision of appraisal management companies.

                Is it really your contention that there’s a lack of regulation in our industry?

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              • Charles Baker says:

                Mike – I’m exhausted refuting your false claims here. There’re just too many.

                You said, “The layering, background checks and other burdens on our profession are originating from lenders, AMCs and FNMA not federal regulators”.

                Perhaps do a little research before posting.  For instance, the following link will take you to the Federal Register document on FEDERAL AMC REGULATION, 33 pages worth.

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                • Mike Ford, AGA, CA AG, GAA, RAA, Realtor ® Mike Ford, AGA, CA AG, GAA, RAA, Realtor ® says:

                  Charles I treated your posts seriously because I thought you were being straight forward.

                  AB624 was proposed BY THE AI to its sponsor through YOUR lobbyists. That sponsor (Mr. Wilk) was also told it was a relatively unimportant “clean up” bill to correct some minor language issues in the original. Such bills are passed as courtesy votes by custom in both Houses. It’s disingenuous to tout it as if it were some great legislative wonder that had both houses held in awe of it. You guys slipped it through and beat the rest of the appraisers in America. AI won! Yaaay for deceit an deception!

                  The TAF opposed the (passed bill) before it went to Senate Finance. The ASA opposed the bill in testimony in Redondo Beach before the TAF and then again in person in Sacramento before the Senate Finance Committee. The AGA opposed it in person (me) in Redondo Beach and again in writing through the courtesy of ASA carrying our letter to Sacramento with their own views. Tell readers again how AI was “speaking for all of us”

                  George St. Johns (President California Coalition of Appraisal Professionals) & I disagree (politely) about what happened next. He coincidentally knew the bills sponsor since he (Wilk) was a kid. He tried to get Mr. Wilk to withdraw the bill by telling him he’d been conned about what the bill did; but he declined at first. There was more follow up.

                  Anyway, Senate Finance Committee passed the bill. I immediately called Guild Headquarters more than a bit disappointed and was put in touch with the OPEIU legislative rep by conference call with Pete Vidi and Leo Regensburger. The next day a call was made by OPEIU to the California Labor Federation.

                  A few days later I was informed the bill had been “buried in the appropriations Committee” where bills normally go to die. To be reviewed in a year perhaps, but believed likely to die. George and I disagree as to what caused that to happen. I’m sure neither George or I will be upset if you want to credit Mr. Martin for burying the bill…for awhile.

                  Two other points about that bill;

                  1. AI DID try to slip it through out of the public eye to the extent feasible. It was an accident TAF and others learned of it; AFTER the fact as it was. By the way, the AI identified lobbyist at that Redondo TAF meeting ALSO claimed to speak on behalf of all appraisers even before IA’s own interests. What? Sounds like all you guys have adopted that as your mantra now. “We are the AI! We speak for ALL the appraisers of America” “Trust us we are the biggest national appraiser group with 20k members located in 60 other countries!” (Did I get that last part right?). I’m guessing AI speaks for ALL appraisers in those  other countries too? Or, do appraisers in those countries know the difference between rainfall and someone peeing on their leg claiming it’s rainfall?

                  2. Immediately after the success of AB624 similar AI pushed bills were introduced in Texas and Louisiana (results unknown); passed in Tennessee and proposed in Illinois.

                  As for your Bill requiring posting of tax stamp amounts on specific recorded pages it had NO IMPACT, or benefit over what was already being done. Whether the amount of the doc stamps (transfer stamps) was shown on the deed itself or on the cover sheet with the same instrument recording number changed absolutely nothing! AI is claiming credit for a procedural item that had literally no change in the way doc stamps were reported or read?

                  OK back to more serious stuff-Once more:

                  THE APPRAISAL INSTITUTE DOES NOT SPEAK FOR, AND HAS NOT BEEN AUTHORIZED TO SPEAK FOR ANY APPRAISERS IN AMERICA OTHER THAN THEIR OWN MEMBERS!

                  STOP Making the claim! The next time I hear it in public meetings it will get the same Joe Wilson response President Obama’s speech got! Maybe tomorrow if your lobbyist is there.

                  From what I read posted by AI members in Facebook and other forums it’s become doubtful they even speak for most of their own U.S. members. Frankly I don’t give a damn whether they speak for the 60 foreign nation members or not.

                  FIRREA was not passed to regulate or adopt the appraisal practices of one foreign nation, let alone 60.

                  Sooner or later the SRAs (like yourself)  and AI residential affiliates are going to wake up and realize AI sold them down the river…again!

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                • Mike Ford, AGA, CA AG, GAA, RAA, Realtor ® Mike Ford, AGA, CA AG, GAA, RAA, Realtor ® says:

                  Charles you treat implementing regulations of legislation applying to OTHER services as if it were appraisal legislation itself?

                  Pardon me but I’m not into sophistry & figurative verbal sleight of hand Charles. Did you by any chance read the title of the document your are presenting as evidence? For all 33 pages?

                  “Minimum Requirements for Appraisal Management Companies”

                  Before YOU post next time,  pull, no wait, go ahead and leave it there.

                  It is YOUR AI’s posted article I’m refuting. YOUR paid lobbyist, Mr. Garber states little appraisal regulatory change since 1989. Was HE lying?

                  I know the Appraisal Institute has increasing difficulty distinguishing between the act of appraisal, and appraisal management companies but there really IS a difference. Appraisal is what you folks used to be good at; heck even respected for once upon a time.

                  Appraisal Management Companies are those companies MAI’s like to set up, manage, or consult for. You know, the ones AI is increasingly cozying up to. No doubt dreaming “Gee if we could only figure out a way to get our monopoly over all American appraisals back again, somehow…MAYBE the world!!!

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                  • Charles Baker says:

                    Mike – It appears you have an axe to grind. That’s your prerogative. I know for a fact many AI members carrying multiple designations and divided loyalties (MAI, ASA, FRICS, IRWA) would disagree with your characterizations, especially those currently serving on the Government Relations Committee itself (of which there are several.)

                    I must simply go back to your initial (rather inflammatory) charge – based on one unnamed source, you believe the AI is actively working to eliminate the ASC.  In the interest of journalistic integrity may I suggest supplying your readers with more information.  I, for one, would be most receptive.

                    This is not personal.  We are both professionals and I respect you’re right to voice your opinion.

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                    • Mike Ford, AGA, CA AG, GAA, RAA, Realtor ® Mike Ford, AGA, CA AG, GAA, RAA, Realtor ® says:

                      Charles, yes. I DO have a specific ax to grind. It is the habit of AI pretending to speak for other non AI appraisers. Inadvertently or not, you also did it in your own post earlier.

                      In the interest of basic honesty (I’m no a journalist nor do I pretend to be one – I’m just an appraiser and a republican-union organizer) Read:

                      It’s a scathing self- indictment by Scott Robinson, MAI, SRA, AI-GRS (former) Appraisal Institute President in his letter to chapter Leaders 11/30/2016

                      1. New York Chapter of Appraisal Institute response, 12/02/2016 (John Katinos, MAI, President, Metro New York Chapter Board of Directors; and
                      2. Lee H. Waronker, MAI, SRA comments 12/7/2016 dumps the entire hamper full of AI dirty laundry out on the front porch and puts to bed the AI LIE that they represent ‘all appraisers’.

                       
                      Apparently AI doesn’t even represent their OWN members. Not MY words. MAI’s words. Don’t skip the references to their underhanded and deceitful practices too!

                      You’re right Charles, it is NOT anything personal between the two of us. I take you as a sincere AI member; proud of your organization but who has blindly stayed uninformed OR been deliberately deceived by your leadership about what the AI is doing; and more importantly in some instances, NOT doing. Charles I respect nearly ALL volunteers. To give valuable time for the good of others is highly commendable.

                      I used to do the same for AARP/IRS/VITA/TCE… until I found out they (AARP) sell the use of ‘their favors’ to any sailor with a dollar, pretty much for any purpose.

                      We can save the part about quitting NAR when they didn’t get their own way, just like they quit TAF sponsorship for the same reason… didn’t get their own way for another days discussion. Best of luck to you personally Charles.

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                      • Charles Baker says:

                        Mike, appreciate the Miller-Samuel link, but we read it the day it came out. It was a hit-piece chocked with misleading hyperbole. “Scathing” as you put it – but mostly false.

                        Lots of conference calls and emails back-and-forth ensued. All Chapter boards were invited to a conference call with National to explain the policy. Other chapters issued their own opinions, some favorable and others opposed.  Our response (SoCal) was measured, acknowledging the merits of some of the changes while expressing concern over others. The fact of the matter is – there are 80 chapters in the AI universe, many of which are small and unable to comply with all the various financial reporting and auditing requirements.  By lifting that burden these chapters were given an opportunity to continue and thrive, serving their members.  The National AI board formulates policy (President Robinson, the other board members and regional representatives) and was perfectly in their right to promulgate these changes. The objections from various chapters centered on the manner in which it was developed along with the reserve sweep. Since then, they realized they jumped the gun and have since suspended the policy.

                        Again, with all due respect – you’re dodging and weaving my question.

                        I’ll ask again (for a 3rd time) – who is your source alleging AI wants to eliminate the ASC? 

                        As an aside, you win the “most use of bold, underscored, italicized text” contest. 🙂

                        Cheers. Enjoy your day at the APB meeting. Several friends and colleagues of mine will be there.  I’m unable to attend due to depo prep.

                        Charles

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      • Diana N. says:

        Excellent Mike…please keep everyone posted.

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      • Charles Baker says:

        Mike – Earlier, you said, “I do not claim, nor have I ever claimed to speak for “all appraisers“.”

        A perusal of the AGA web-site | About Us, states:

        “If you are a professional real estate appraiser, the AGA has already represented you in discussions with national level and state level appraiser regulatory organizations during the last several years of unprecedented change in the appraisal industry. This has included meetings with Fannie Mae, Freddie Mac, the GAO, the Federal Reserve Board, state appraisal regulators, state banking agencies, high-level political leaders crafting legislation and other decision-makers who will decide the future of the appraisal profession for years to come.”

        I’d be interested to know how the AGA has represented me, an AI member.  Seriously.

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        • Charles, by fighting for minimum reasonable and customary fees; but let me correct our clear unintentional error. AGA does NOT represent Charles Baker or any other appraiser seeking to destroy our profession for their own selective group benefit.

          Charles if all you can do is criticize bold face fonts then I submit it is you that is avoiding the issue, and engaging in sophistry instead. Which part of the Miller article was a hit piece? The Chapter President’s response to the power grab or the MAI member’s response?

          I’m beginning to understand. Anything the AI disagrees with is a hit piece, right?

          As an aside, there were three identified AI members at the recent TAF meeting in Torrance. I didn’t hear your name among those present.

          Two actually had positive suggestions: (1) TAF needs to consider developing a data library similar to the AI LUM Library; and (2) TAF and AI need to look into the possibility of sharing the existing LUM Library with all appraisers as a potential road to reestablishing constructive relations with each other.

          Our back and forth comments must have served some good. Not one AI Member claimed to be speaking for anyone other than themselves this time.

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      • Baggins Baggins says:

        LICENSED IN 15 STATES!?

        Credibility; Denied.

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  4. Apologies for posting here-Webinar is tomorrow – I just learned of it. FREE HousingWire Webinar — Wednesday, March 1

    I was originally mildly annoyed with my favorite National Membership Coordinator for sending me a link without telling me what it’s about.

    This is for a webinar registration that features a cast of characters that alone makes it worth attending or watching.

    It’s titled “What’s Going to Happen to Appraisers in 2017”. It’s to be moderated by Jacob Gaffney, editor of Housing Wire.

    Usually I’m pretty careful about who I give an opportunity to pollute my mind but this cast of characters includes a truly noteworthy Rogues Gallery. Their bios are interesting.

    “Brian Coester, CEO, Coester VMS “For nearly a decade, Coester has immersed himself not only in the appraisal industry but in the mortgage industry as a whole. As a certified appraiser, he has a firm understanding of what is important in a valuation and how it affects the industry.”

    Alan Hummel, Chief Appraiser First American Mortgage Solutions (Anyone remember the folks that bought ACI or developed PACE PRO?) Now for the good part:

    “Alan is a past national president of the Appraisal Institute and is also a representative member on the Appraisal Subcommittee Advisory Committee (ASCAC).

    Zachary Dawson, Director Collateral Strategy & Policy. FannieMae “Responsible for Fannie Mae’s Single Family collateral strategy as a whole, covering both Selling Guide policy and use of collateral technology tools including Collateral Underwriter®. He also oversees the Appraiser Quality Monitoring initiative, collateral analytics & reporting, and other strategic appraisal initiatives”

    I’m deliberately leaving the fourth off because I have no knowledge of them other than info that speaker is a reported partner in a multi county Florida appraisal firm owned by MAIs, and that he is a former Florida State Regulator.

    Seeing who the featured speakers are helps us to better understand why the state of our profession is what it is today.

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  5. Wayne says:

    To whoever…

    I have been in this game for over 40 years. I have at one time or the other paid dues to the AI, IFA, SRWA, etc. Really I believe that the AI is one of the most harmful organizations in the appraisal occupation. I vote with my money and I do not send it to them. I do not believe they are any friend of a residential appraiser. Just my silly opinion. Just saying that we have too many parasites in this occupation and that will be our demise. Keep sending dues and they will use this money to kick your ass! Instead…spend same money with me to go on fishing trip..or a gambling trip…you will have more fun and I charge no fee! I am no travel agent…just wanting fun friends to go along! LOL Really we do not need to support “trainers” “Coaches” “Expos” and all of the other leaches in our occupation. Do we not have enough problems without these folks? I am about to retire…these words are sincerely sent to those trying to earn a living at this! I no longer have a dog in this fight. I live in TX and spent last week in Las Vegas, I will be spending next week on a Carnival cruise along the Pacific side of Mexico. Back to Las Vegas in April and July…I am just enjoying life and having fun! No need for me to steer my fellow appraisers wrong. I really wish you the best!

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    • DianaN says:

      Have a great trip, weather has been very good there and no problems except what to order for dinner and what to drink at Happy Hr. 🙂

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  6. Mike Ford Mike Ford says:

    Charles wanted ‘my source’ of the rumored changes. He’s right, I am NOT going to divulge it. That’s the fastest way I know of a source turning into a complete stranger the next time a critical issue arises.

    But Charles and others may share an obvious & legitimate concern. Who other than this Ford guy can confirm or refute, or clarify the rumored attacks / proposed elimination of ASC and TAF right alongside Dodd Frank?

    Here are the staff contacts I was given. Some are democrats and some are republicans. Between them you should be able to get a good feel for the direction of any pending legislative efforts. It’s also a great opportunity to offer your own views on what’s right or wrong with Dodd Frank; ASC, TAF, It’s Boards and any concerns over possible changes in FIRREA.

    Please be the respectful professionals I know you to be. We’ve always asked “Who can I contact?” Well. here’s the answer (on this issue anyway).
     
    Theresa Dumais, Director of Housing Policy Committee and Financial Services.
    Congresswoman Maxine Waters (D) CA., ranking member of the House Financial Services Committee
    (202) 225-4247
    Theresa.dumais@mail.house.gov

    Perre Smalls, Legislative Aide
    Congressman Wm. Lacy Clay (D) MO., ranking member of the House Financial Services Committee, Subcommittee on Financial Institutions and Consumer Credit
    (202) 225-2406
    Perre.smalls@mail.house.gov

    Andy Taylor, Deputy Chief of Staff and Chairman’s Designee
    Congressman Sean Duffy (R) WI., Chairman House Financial Services Committee, Subcommittee on Housing and Insurance
    (202) 225-3365
    Andy.Taylor@mail.house.gov

    Erin Barry, Staff member
    Senator Mike Crapo (R) ID. Senate Committee on Banking, Housing, and Urban Affairs
    erin_barry@banking.senate.gov
    (202) 224-7391

    Matt Jones
    Professional Staff
    U.S. Senate Committee on Banking, Housing, and Urban Affairs
    534 Dirksen Office Building
    Washington, DC  20510
    Phone: (202) 224-0348
    Matt_Jones@banking.senate.gov

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  7. Mike Ford, AGA, CA AG, GAA, RAA, Realtor(r) Mike Ford, AGA, CA AG, GAA, RAA, Realtor(r) says:

    Charles if you are still interested in my “source” I’ll give you ONE of them. It’s the Appraisal Institutes own paid lobbyist. See page 10. Note: Several of AI’s proposals might well have been favorably received and supported by other organizations of appraisers… IF they had ever been consulted. Not all of the ideas are ‘bad’ per se.

    Two of the worst ones though are sunsetting the ASC or TAF; and an NMLS type license. A federal license to be regulated by individual states that can’t even handle managing USPAP compliance or C&R fees? No thank you!

    An excerpt from:

    Testimony of William E. Garber, Jr.
    Director of Government and External Affairs
    Appraisal Institute

    Before the Subcommittee on Housing and Insurance
    Part 3. Legislative Reform Options

    As Congress reviews appraisal issues, we would like to suggest several reforms to help improve appraiser oversight and enforcement, as well as the overall quality of appraisals.

    With regard to the appraisal regulatory structure, we offer the following suggestions:

    1. Realign the appraisal regulatory structure similar to those of other professions in the real estate and mortgage industry. One model that merits consideration is the National Mortgage Licensing System (NMLS), which is a cooperative among state agencies overseen as a last resort by the Consumer Financial Protection Bureau (CFPB).

    2. Sunset the Appraisal Subcommittee, while maintaining the authorities of state appraisal boards, and align the federal functions with a nationwide portal like the NMLS. This would provide services in one place for appraisal practitioners, appraisers working for financial institutions, and appraisal management companies to apply and renew appraisal licenses and registrations.

    3. Authorize a federal backstop authority consistent with other regulatory systems authorized by Congress in recent years should states fail to adhere to basic program requirements.

    It’s a cut and paste of the entire PDF section. I have not omitted anything and pasting here may have affected the format. Any that want the original document as I received it. Just send me an email.

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    • Tom C says:

      Mike, interesting back and forth between you and Charles. Have you listened to Jim Park’s interview with Phil Crawford? He confirms a few of the points you were addressing in your comments. Looks like Charles threw in the towel. Thanks for keeping them honest!

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      • Hi Tom, I’ve heard Mr. Park’s view and tend to agree with him. I had an opportunity to meet and speak briefly with him at the recent TAF meeting in Torrance, California.

        At that meeting on behalf of the American Guild of Appraisers I had the privilege of announcing AGAs continued support of the ASC; TAF, and all of it’s boards “without reservation.”

        I did back peddle a bit from my written submission made prior to the hearing where I called for the gracious elimination of all non real estate appraiser disciplines form all boards as running contrary to the intent of FIRREA.

        It’s an economics issue. ASC is the smallest federal agency in the country with only 13 staff employees. It is reported to be fully funded by appraiser fees. TAF on the other hand is a private (federally monitored) entity that only received about 10% of its funding from our fees and publications (like the necessary USPAP purchases every two years).

        The remaining 90% comes from TAF sponsors. Like it or not, if other entities are paying for a  seat at the ‘TAF’ table, they inevitably get a proportionate say in how things are done.

        I’m not fond of the idea that so many non real estate appraisers are voting or deciding on policies that primarily affect real estate appraisers but not themselves (we are the ONLY ones required to be licensed  under USPAP). This unfortunately must remain a conversation for another day.

        Thanks for the kind words.

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      • Charles Baker says:

        Hello Tom & Mike – haven’t thrown in the towel. Just extremely busy.

        Earlier in this thread Tom said, “Hi Charles, the AI has not made a public announcement stating they seek to eliminate the ASC. THAT comment came from a source who met with House Members and others who advised him that was the intent.”

        After some encouragement, you cut & pasted selected excerpts of Mr. Garber’s PUBLIC testimony before the Housing and Insurance Subcommittee. Was this your “non-public” source for your initial charge? If so, I can accept that. Mr. Garber offered a number of proposals to untangle our current regulatory oculus, each worthy of consideration and debate. But by no means is the AI attempting to pull the wool over anyone’s eyes.

        As an aside, talks are underway to bring AI back to the table as a sponsoring organization of TAF. One would think that if AI were actively pursuing the elimination of the ASC they wouldn’t bother.

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        • Charles the issue remains the same. AI IS attempting to have the ASC eliminated. Garber’s written testimony is only a small part of a growing mound of evidence. You can either accept it or not.

          No. he is not and was not my primary source of information. As I already mentioned, that source remains just that-my source. You can hinge your argument or acceptance on Garber’s suggestions though.

          As for AI becoming a TAF sponsor again, I’d personally hate to see that. AI has proven themselves to be more than willing to throw the entire profession under the bus for the self serving interests of a very few among them.

          Just my personal opinion though. AI should participate in TAF public meetings the same as everyone else is forced to do. “Buying” influence or a seat at the table may be good for the AI but it hardly benefits the majority of the profession who are not AI members.

          I like & support the idea of a private enterprise (TAF) remaining somewhat semi independent of the feds (limited monitoring) but I am exceptionally concerned about the influence of non real estate disciplines being exerted over purely R.E. appraisal issues. This includes basic qualification criteria for real estate appraisal licensing and CE course content. Those interests are not subject to the same licensing laws or regulators under FIRREA that we are.

          What genius thought it would be a great idea to let them make all of the rules for OUR profession?

          Unfortunately, according to TAF Members speaking at the recent Torrance, CA meeting funding for TAF is only about 10% from licenses. The other 90% is from the sale of publications and SPONSORS.

          I can’t think of a viable alternative that would be both fair to all stakeholders and politically acceptable right now. Until one is found the future of all real estate appraisers is being driven by a pay to play behind the scenes consortium of special interests.

          PS-glad you are staying busy if it is at appraisal rather than special interest lobbying.

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  8. Charles Baker says:

    Mike – I earn a living appraising. My work with AI is entirely on a volunteer basis.

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AGA

AI’s Effort to Eliminate the ASC!

by Michael Ford time to read: 5 min
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