Another Appraisal Waiver Request

VaCAP Board

VaCAP Board

Coalition of Appraisers in Virginia at Virginia Coalition of Appraiser Professionals
Coalition of individual appraisers working together to unite, promote and protect the collective interests of all appraisal professionals in Virginia; to promote needed changes in laws, rules, regulations, policies and standards affecting all appraisers in Virginia; to observe and report the actions of regulatory, legislative, oversight, and standards-setting entities of the Commonwealth.
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Another Appraisal Waiver RequestAnother Appraisal Waiver request has been sent to the ASC. This time from City Bank and Trust in Oklahoma. The bank is claiming a shortage of acceptable appraisers in the area.

Their solution:

“Our bank has on staff an individual who has maintained a Certified Residential Appraiser license until April 2017. This individual has provided acceptable appraisals and evaluations for the past 20+ years. He determined to allow his license to expire due to the rather burdensome CE requirements and the distance to and from approved course within the state.

With the educational requirements, training process, number of hours required by the state, there is very little incentive for an individual to pursue obtaining an appraisal license. Most people cannot afford the time it takes to become licensed. Additionally, it is more difficult to find people in the Oklahoma Panhandle desiring to spend the time and effort to conduct appraisals in this sparsely populated part of the state.

Speaking for our bank in particular, we believe we have staff in the bank with lengthy experience in knowing our community. They have a good understanding of our local market, develop and document values and trends on an ongoing basis and are competent to produce evaluations and appraisals sufficient in nature to assure reliable valuations of real properties.

Therefore, we respectfully request that we be considered for a temporary waiver pertaining to the certification and licensing requirements.”

See the  letter of request here.

VaCAP, along with many other appraisal organizations have sent a letter to Jim Parks concerning the Appraisal Waiver request from TriStar Bank. TriStar Bank is in Tennessee and requested a waiver a few days ago.

See the letter here. 

We are concerned this could become a fast growing trend. If the ASC grants these waivers, the door will be opened for all others to follow. Now, more than ever, it is time for appraisers to come together. Get involved with your coalitions and other professional organizations. Contact your State and Federal Legislators. This is our profession and we are here to protect the public. Appraisal Waivers do not protect the public!

To join, donate, volunteer and support VaCAP, click here.

Image credit flickr - Charlotte Cooper
VaCAP Board

VaCAP Board

Coalition of individual appraisers working together to unite, promote and protect the collective interests of all appraisal professionals in Virginia; to promote needed changes in laws, rules, regulations, policies and standards affecting all appraisers in Virginia; to observe and report the actions of regulatory, legislative, oversight, and standards-setting entities of the Commonwealth.

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101 Responses

  1. Candy Watts says:

    Every time a bank does this, every licensed and certified appraiser in that state should sign up with that lender so then the lender can no longer say they don’t have enough appraisers. They just don’t have enough appraisers to work for $200. The word needs to go out to every state coalition so they can get the word out to all the appraisers in their states. Lets fight these lenders at their level. They obviously don’t care about our bottom line, they only care about theirs. Appraising is how we feed our families and put our kids thru college and pay our mortgage. As much as we would like to think the system as it is will make the right decision. Well that is a load of crap. The system is broken. If we want to continue to be able to make a living as appraiser’s we need to fight back and being nice about it does not get anyone brownie points.  If a lender asks for an exception in our state let all of us know. Then we all need to sign up with this lender. Lets get the word out and fight back against these lenders. They messed up the real estate markets all over the US(and some say internationally too) and single handedly cause the crash of the economy. If we stand by and do nothing this time, then we are all just as guilty the next time it crashes. We may be small but we are mighty and unified we can make a difference. There is strength in numbers. And if we really want to show these lenders we can carry a big stick. No orders should be accepted by any appraiser in the state from these banks. If they can’t get any loans completed it could hurt their bottom line.  

    Whatever we do, we need to be organized and stand together.

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    • I like that idea! Everyone within say an hours driving time (to two?) write them and commit to appraise for them at C&R fees.

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    • Koma says:

      Candy, That’s the whole point. They do not care about us! When we have a bank that illegally sets up fake products in their customers name, others that set up/buy AMC’s that take half of appraiser’s fees and now are going to push for PIW’s do we really need a hammer to hit us on the head to figure it out?

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    • Baggins Baggins says:

      Absent a state mandated union there will be no cohesion to any boycott effort. Free market principals apply and consumers dollars will continue to drive the market. The lender has no ‘right’ to lend. If they’re unable to source talent to comply with checks and balances systems, they should be allowed to fail and another allowed to rise up in their place. Fractional reserve lending allowance continues to accelerate the market.

      Check out this banks numbers here

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      • Baggs, doesn’t it strike you as strange, that the only appraiser union in the country (I don’t count SEIU & its selected government employee appraisers) has never called for, or even suggested appraisers strike?

        We have urged individual clients that have publicly proven themselves to be dishonorable be boycotted, or at least contacts made minimal.

        Appraisers do not want a  strike. Appraisers will not support a strike. There may be other traditional union methods of opposing unfair or abusive tactics but unless the personaities of appraisers change drastically – striking wont be one of them.

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        • Baggins Baggins says:

          I was on a one man amc strike back when that wasn’t cool. I’m currently on a low fee strike. Soon I’ll be on a hunger strike if these desk managers don’t stop constantly trying to short their appraisers. What’s strangest to me is the way otherwise decent Americans feel it’s acceptable to treat appraisers like dirt, simply because we’re not direct members of their team. Shame on the lenders and their associates for not respecting the golden rule. My name appraiser. I am professional punching bag. Pay me, that is my only reward and only motivation I have left to stay in this ruthless heartless god forsaken industry.

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          • Lol.

            Baggs, I don’t accept that people that can turn their sense of morality on and off like a switch when they go to work are ‘otherwise decent Americans.’ They are pond scum. There’s a huge difference between honestly motivated people seeing the ‘line’ of propriety in slightly different locations than there is from pond scums belief that there is no line, and that if their were a line its ok to hide its location from everyone else.

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            • Baggins Baggins says:

              This industry attracts the most aggressive, that’s what’s difficult to convey to people. The day after waivers abuses will be instantly rampant. Tunnel vision to the pot of gold.  They don’t even work weekends, trolls in cubicles, somewhere in the sky.  Wait strike that, I need continued orders.   Better play nice, that’s the only way to appeal to someone not qualified to understand what I’m talking about in the first place.  My life is a catch 22.

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  2. realrose says:

    These banks are probably headed by a republican; they feel entitled to get anything they want as along as the republicans are in control. Both states whose banks wrote for waivers are red states; actually are few real republicans left as they have been taken over by the tea party, who represents these hillbillies. I guess they think it takes no education to develop an opinion. The koch brothers funded the tea party and they are now represented by the libertarians whose motto is “I got mine, screw you”; they are like the billionaires who manipulate, cheat and pollute our waters like the koch brothers who want to build more oil refineries, but EPA rules are expensive; since they have the money from their big donors, nothing is happening but tearing down protections we had like the Consumer’s Protection Bureau, EPA, Health and Human Services, HUD, etc as Bannon and his followers get what they want which is power (because they already have tons of money). and their goal is to “deconstruct the institutions” America has developed since its beginning, and up to the time when congress stopped working for the people and served their donors exclusively. All the money, time and experience I have, including a designation have been trashed. All those libertarians think they should be able to make mega millions without limits! This is just the same environment that caused the great depression. The American Institute of Real Estate Appraisers (AIREA) was formed to protect the citizens from financial fraud like exists on Wall Street.  As long as citizens are making money in the stock market, then they won’t do anything as long as they are profiting.Capitalism needs limits to what one can do to make money, but republicans, funded by wealthy donors, ala Citizen’s United, and Fox news, Limbaugh, Breitbart and other fake news sites are able to brainwash their followers, I have very little hope that real estate appraisers will not be destroyed in the greed fest led by trump, who is the biggest con artist that ever hit our political landscape. I would like a waiver of any requirements, but I follow the rules set forth by USPAP which came from the AIREA; now the political organizations who now take credit for making appraisal a real profession with real education and high standards has become a joke. The Appraisal Foundation has on their web site a claim that they are the foremost authority on real estate appraisal…. tell me another lie, but I am not a Fox hound, and I can smell a rat after almost 40 years in appraisal and 50 in real estate, so I can see right through bias, and these banks think they can get even less accountability because the citizens will bail them out again; that is what we call a “moral hazard”. The AIREA got contaminated by the Society of Real Estate Appraisers who were bank appraisers and that is the problem; the two organizations have joined in 1990, and the merger made us lose ground when the AIREA held the “high ground”.  Many think they abandoned the residential appraisers; actually, licensing dilluted our designations and lobbyists who were highly paid by realtors and banks won. We are just not acting in our own self interest, and we don’t have enough money to fight Wall St., banks and realtors all of whom are wanting a blank check from the American tax payers to allow them unfettered greed. I’ve had clients like trump who owned big trophy properties, and they lied to me; experience helped me recognize this and I took their info, checked out their comps, accepted or rejected them, and kept them in the workfile; if it was a court testimony, they were in my “sales not used” file so if the opposing attorney asked me why I didn’t use 123 Main street as a comp, I already had it in my file and could say it was too big, too small, too far, too dated, or too different in some important way. If you think we can practice this profession ethically and profit, as long as there are people with lesser standards and ethics, no limits to what a bank can do to secure a loan, and while private Fannie and Freddie dictate the forms used, methods to steal our data and co-opt our licenses by the pimp AMC model; greed will win the day, and we will be bailing out banks again for their greed.  

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  3. Mike says:

    The coalitions and other organizations are all over this topic. If you are not part of any organization, you need to know that others are working very hard for YOUR BENEFIT. Please get involved. We are all appraisers and if we do not come together as a profession, we will not have a profession. Please get involved.

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    • Baggins Baggins says:

      Our profession is checks and balances. Are we the only independent group left in the entire lending community? Based on the substance of the request I think a fact check is in order. Another poster mentioned the possibility the individual staff appraiser in question may not be able to renew. We’ll need this individuals name please, and the zip codes of this location to run the standard appraiser availability search. These actions are a clever way to redirect the entire appraiser income pool towards major corporations and unregulated technical staff. Tech wizardry at it’s finest. Have faith in tech, because we’re writing god and faith in man out of the books now a days. Pretty short sighted and selfish of the bank to never incentivize the staff appraiser to train anyone for the future don’t you think?

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  4. Hmmm. I sometime have to rephrase these things so I don’t get too confused. I’m getting really old and decrepit according to all the Big Data I see.

    The bank has some guy on staff that USED to be an appraiser. That was before he stopped being an appraiser.

    Those pesky license requirements, like relevant ongoing education and performance in accordance to required standards just really proved to be too inconvenient for him.

    He is not presently qualified or competent to appraise anything related to a federally regulated transactions but we did give him an impressive executive title.

    My only question is “Why can’t all appraisers in all states and territories be given the same waiver from standards and accountability this bank is asking for?

    That will fix the shortage, fee issues, turn around time, and uncooperative appraisers because we could all give opinions from the comfort of our desks for a couple of Moon Pies and an RC Cola*.

    (*RC cola may also be waived in event of sugar or sugar substitute price increases of more than 1% in any ten year period. The Moon Pies compensation requirement may not be waived nor reduced to less than two in number under current C&R fee requirements. Reduction in the size of each pie is still permissible at the discretion of the clients).

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  5. Xpert says:

    It’s good to see so many appraisal organizations working together.

    Personally, I don’t think CRN is helpful to the profession nor looking out for appraisers’ best interest. Cross reference the Network members and determine for yourself which is which…

    Collateral Risk Network Members

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  6. Baggins Baggins says:

    For a non appraiser to actually believe that distance is prohibiting access to professional CE for appraisers demonstrates their severe lack of first hand knowledge regarding the qualification processes at hand. Last time around I used career webschool and that was cool, just a non stop multiple choice approach and repeating modules if you don’t get it, time consuming but rather simple. This time I’m using mckssck and am in around 700 for per diem classes. If these guys get a waiver for using appraisers, I want a waiver to pass CE for at least a cycle.

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    • Baggins Baggins says:

      Well I must be fair and update this statement. Per OK appraiser above, must take half CE offline. You know what that is pretty awful. But please inform me why you don’t charge enough to make it worth your time, to the point the standard requirements become ‘hardships’? If your government is not working well for you and is acting like a bully, get in there and push back. We The People. The price of liberty is eternal vigilance. And to follow my comments in similar related threads; The lenders are very short sighted for not helping the appraisers get access and incentivizing a more robust appraiser populace, but instead they take this weak spine crybaby need a waiver approach. Where is my waiver, where is my bailout, where is my subsidy? If the lender can’t play by the same rules as the rest of us, out with the old and in with the new, off with their heads. They’re not lords, they’re not elites, or the privileged class, they’re just lenders. Let them participate in the free market like everyone else or let them fail. I’m ready to go to OK today to provide those services. I’ll only charge 4x my normal rate of $550 per report. Incentivize me and I will go there and get reciprocity, and even be willing to train someone as I go. Reality check, it’s a free market system.

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  7. Baggins Baggins says:

    Woah!  My crystal ball was glowing this morning and my wookie senses lit up.  There is going to be a brand new petition for appraisers and it’s going to be bigger than the hvcc era.  We’re going to be unified like never before through a common cause and common threat.  Stop the waivers!  If there is a crushing blow that can dismantle an entire industry of 70,000 independent American real estate workers, that’s likely to be it.  We as a country are focused on creating jobs, not outsourcing the jobs to the already employed with tech giants, likely overseas, casting off vital and long standing checks and balances systems for the sake of convenience of lenders.

    What do you think of this one? Per the Congressional Research Service, June, 2012.

    https://fas.org/sgp/crs/misc/RS22953.pdf

    /  The Housing and Economic Recovery Act (HERA, P.L. 110-289) included a provision designed to increase the independence of appraisers. It prohibited mortgage lenders, mortgage brokers, mortgage bankers, real estate brokers, appraisal management companies, employees of appraisal management companies, and any other people with an interest in a real estate transaction from improperly influencing, or attempting to improperly influence, the development, reporting, result, or review of a real estate appraisal in connection with a federally related mortgage.&

    The October 2010 rule contains five major provisions.  It prohibits coercion of appraisers to influence the appraised value of properties. It prohibits appraisers and appraisal management companies having financial interests in the transaction. It prohibits lenders from providing credit if they know beforehand of violations involving appraiser coercion or conflicts of interest.

    The October 2010 rule is broad. The covered transactions that it applies to are extensions of consumer credit that are or will be secured by the consumer’s principal dwelling. This includes home equity lines of credit. The rule is not limited to appraisers. It also applies to any person who makes a valuation of real estate for a covered transaction, including real estate agents. &

    The FIL makes a number of substantive changes and clarifications to permitted methods of collateral valuation by banks. It states that automated valuation models and similar technical systems cannot be substituted for an appraisal when the transaction requires an appraisal. It prohibits covered lenders from relying on valuation methods that do not provide a property’s market value, such as a broker price opinion.  &

    The agencies stated that the independence of the appraiser is compromised if the borrower recommends the appraiser or bank’s loan production staff selects the appraiser. The FIL requires banks to separate their loan officers from the staff that selects the appraisers.  (My addition:  By moving to waivers, evals, and avm’s, the lenders are circumventing rule sets and could then be in control of selection and result process.  They should also be prohibited from selecting or running their own avm, eval, or other ‘appraisal substitute’, and perhaps that could be argued based on these rules, they should be prohibited from doing so.)

    And some other jargon in there.  In the end, mention of limited denial lists and such.  So I suppose if we move to evals, then HUD will have to respond with a new denial list for certain eval software, build even more bureaucracy to have a new tech staff to analyze eval results in leu of traditional appraisal process, and so on, and so forth.  This seems like an unnecessary effort when over 70,000 appraisers remain.  We need to replenish the ranks with a reduction of operational pressure and constant financial and working stress factors.  The new standards of 48 hour turns, 1 week total allowance, fee bidding, re assignment, selection primarily through automated methods for fee and turn time, irrelevant grading, having to appeal to unlicensed often inadequately informed people to source appraisal orders, it’s all misdirected and counterproductive to the true cause of the appraisal valuation industry, which is protecting the public.  Protecting the public and their continued access to lending availability to fulfill the American dream. If lenders are simply required to use appraisal services more rather than less, that will promote a renewed vitality in the appraisal industry and solve sourcing problems.  Lenders created sourcing problems themselves, they should not be allowed to opt out of the requirement as a result of their poor and irresponsible business practices pertaining to dealing with appraisal professional servicers.

    All this regulation is not about the protection of lenders, it is about the protection of American lending consumers.  Waivers are not necessary and do nothing more for lenders than redirect their regulatory compliance and allow them to circumvent existing rule sets.  Appraisers are or can be made available to any given lender in any US local or US abroad territory, with the right and fair financial incentive and fee structure to support relocation and appraiser business growth.  If a lender can source mortgage brokers, they can source appraisers.  If they can source underwriters, managers, ceos, even regular clerks, they can source appraisers through similar and familiar processes. The popular lender approaches to sourcing appraisers have resulted in a remarkable attrition of over 130,000 appraisers in a 10 year period.  This attrition of professional servicers is a clear representation of abuse of power and abuse of intended process compliance.  I urge any person in a position of decision making authority on this matter to become better educated and consult with appraisers whom are truly independent and not beholden to lender or management company interests, before reaching a decision.  Also I believe one body should not be in charge of this decision and waiver allowance should require more than a letter to the ASC, it should require approval from the head of the CFPB and all other regulators whom may be involved in the securitization process with the lender or lending entity which requests a waiver.  A few limited persons should not be in charge of the future of an entire industry of hard working licensed professionals.  Consumers whom present to lenders with good credit and low risk factors should not be denied access to appraisers for convenience of the lender.  More valuation security is better, it was not very long ago the regulatory bodies were arguing for second appraisals provided by human valuation professionals.  I do not believe that an evaulation or substitute for human appraisal services can maintain similar independence or critical standards to mirror the existing checks and balances which professional appraisers provide.  Thank you.  I am a certified appraiser in the state of Colorado.

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    • Baggins Baggins says:

      O.k., I spent about three hours on that research and letter this very morning.  Mr Ford and whom ever it may concern, please feel free to use this letter or any content therein as your own.  For persons interested in this issue please also read the entirety of the Congressional research report which is linked above, as I have only copied in select portions into that official government report into the above post.  Also I have a handful of hvcc era letters from NAR and other interested organizations whom rely on the vitality of the appraisal profession which support the arguments presented in favor of renewing the appraisal industry.  There are so many opinion letters out there though, I feel it’s more productive to review the final reconciled analysis reports if the goal is to argue for or against a regulation or proposed change to regulatory structure.  Thank you.

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      • Thank you Baggs! Great job. I read and save a copy of the Congressional Research Report linked. I’m a little conflicted in thought right now.

        I think Jim Park over at ASC is perfectly capable of impartial and unbiased analyses of a banks purported need for a waiver. His is a small federal agency though (13 total employees I think). Political pressure has to be considered a very real possibility if not probability.

        I’ve spoken with Mr. Park on several occasions and I personally do not think he would ever cross the line due to pressure. On the other hand, special interest rewriting or reinterpreting the laws that he operates under is beyond his control.

        The evaluation alternatives were written into FIRREA. I don’t think Congress ever expected what they thought to be a prudent emergency measure would be twisted into a tool of convenience for lenders to actually subvert the intent of FIRREA. Not so close to the S&L crisis anyway.

        TAF sponsors just appointed a Board of Trustees Member that cites appraiser experience at WAMU, and working for CoreLogic as his credentials. He may be a wonderful person, but I am beyond uncomfortable that TAF would allow the appointment of someone tied to an organization that was partly to blame for HVCC; and another one that is so actively seeking to undermine the integrity of the appraisal process.

        I submit that TAF met and long ago passed its Congressional mandate. (1) State appraisal tests were certified as adequate; (2) USPAP was established (it really does not need to be tweaked every two years); and (3) They have crossed over to trying to make real estate appraiser standards and principles match those of non real estate appraiser disciplines. I don’t recall FIRREA telling them to do that. (4) Lack of consistency and continuity in USPAP since 1991 has led to less trust by the public, rather than more.

        Maybe its time for a TAF sunset clause. How often do well thought out rules have to be tinkered with anyway?

        I doubt there is an appraiser in the country that could or would credibly argue a FIRREA based rationale for changing ‘principles’ or the standards for their implementation according to a two year calendar.

        Yet amid all the unnecessary tweaking, twisting, reinterpreting and accommodation of sponsor needs, TAF has never managed to urge or develop a policy that would result in Dodd Frank Act mandated reasonable and customary fee enforcement; OR an economically viable way of encouraging new trainees.

        …at least not one that didn’t favor affiliate sponsors &  AMC advocates.

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        • Baggins Baggins says:

          Thank you.  I was searching for an online version of this pro appraiser NAR letter I had saved pdf but was unable to upload.  Instead I found that report, probably much better.  They’re all beholden to something akin to sponsor and content control these days.  Don’t act up or you’re next, that seems to be the theme of the appraisal industry over the last 10 years.  Myself, I’ve never been very good at following orders unless they make sense to me personally.  We The People, in order to form a more perfect union…..  Yes, I really do have a copy of the Declaration and the Constitution on my wall, I review them every time I have a cigarette in the garage.  You know what you’re talking about, I just regurgitate legal facts with an attitude.  I hope you continue to make strong headway.  Thank you.

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          • There is a teensy, tiny, little, infinitesimally small chance I might be perceived by some as having ‘acted up’; strayed from the clone reservation, or not being as cooperative to industry interests as they’d like.

            But I’m not sure what the downside is.

            PS-thanks, and I keep a pocket booklet on the kitchen table so any time my daughter has a question about it she can find the answer without someone else’s interpretation.

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  8. wtemple says:

    I would suspect, and I am just guessing here, that the ‘appraiser’ who gave up their license did this so they can run all the AVMs the lender wants, using their experience as a guide. No license, no state requirements, no USPAP.

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    • Baggins Baggins says:

      The lender is going to have to do the unthinkable. They’ll have to put out a help wanted sign and compete for labor services. How on earth are they going to accomplish such a complex task?

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        • Baggins Baggins says:

          Game over. That’s not how I thought that would play out. Outsource to whom, by their own argument there is a lack of talent. I’m willing to move to, where was this again? All I need is a salary equivalent to their top mortgage banker and standard relo expense benefits and housing. Fair is fair. If they can source MB’s, they can source appraisers.

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          • Lol – sorry baggs, you would be too expensive. I am forwarding a name from a young lady  whose email I received last week.

            She started out by saying she is located in India. No deception. I like that. She will do any marketing, typing, appraisal form filling, IT or any other online tasks an appraiser could think of, for only $5.00 an hour.

            Not knowing an Oklahoma would need a Girl-Friday to do their appraisal evaluations, I foolishly deleted her email, but all they need to do is google “Linda Andersen, India”.

            I know its a huge population, but what are the chances of there being more than one Linda Andersen, native born Indian?

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            • realrose says:

              I got a call last week (12-8-17) from an Indian person named Tony Judkin from Infinity International, he said of Rockwell, Maryland. Phone number 443-283-3499 came up on my caller ID. He said they are a “data” company and he will type my reports. I told him I don’t need any unlicenced guy from India who doesn’t use his real name to get involved in my business.

              We need to report these incidents to the State offices of Real Estate Appraisers and alert them there are fake, foreign entities trying to capitalize on our licenses, and who are probably owned by banks and other lenders who are preying on us because we have a licence, published on their website. Being an appraiser with a license has provided opportunities for unscrupulous bankers and other crooks to take up our time and waste it with unsolicited offers to take our businesses away. Of course, they can change their names, company names, places of business and try new tricks every time they morph into another con; we are prey. REPORT THESE TO THE STATE BUREAUS!

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  9. Baggins Baggins says:

    FDIC rules for appraisers. Related;

    5000 – Statements of Policy – Interagency Appraisal and Evaluation Guidelines

    Appendix A, appraisal exemptions. For particular individual considerations only, and always use an abundance of caution. Throw that blanket covers all exemption request immediately in the trash can. Look, it’s right there, see for yourself, the exact wording. That request belongs in the trash can.

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  10. Fritz lewis says:

    Staff Appraisers are the true definition of pond scum. Cant make it on your own? Booooohoooo

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    • Fritz thats overly broad and inaccurate. I’ve been a staff appraiser. Title company sold our division to one of our marketing people (that I hired) because they were willing to ignore rules (USPAP was brand new) and I wasn’t.

      I know many good, even great staff appraisers. We ALL sought staff positions once we were good enough because having predictable income is sometimes a nice luxury. By the way, most staff appraiser positions today have less than a three year life expectancy, so its become much less attractive. Give up your own practice for three years and ten have to rebuilt all over again. Up until HVCC Bank of America Trust Dept. staffers were some of the best in the country. Heck, even FNMA USED TO have good appraisers.

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  11. James Scholl says:

    ASC IS LOOKING FOR PUBLIC COMMENTS ON WAIVERS (link below);

    My posted comments to ASC; “I believe many others will comment against this proposed folly. So I will simply ask this; if the waiver is granted please require the requesting bank to formally notify its depositors and shareholders of the action and also compel them to include dissenting views from others including appraisers who have been requesting inclusion onto the banks panel of appraisers for some time. Thank you.”

    Appraisal Subcommittee; Notice of Received Request for a Temporary Waiver

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  12. Robert P. says:

    ASC Special Meeting – April 12, 2018 Tuesday March 06, 2018 The ASC will hold a Special Meeting scheduled for 10:00 a.m. on April 12, 2018, at the Federal Reserve Board facilities at International Square, 1850 K Street NW, Washington, DC. The purpose of this Meeting is to consider the temporary waiver request from TriStar Bank of Dickson, Tennessee. The agenda for the Meeting will be posted here approximately two weeks before the meeting date. If you plan to attend the ASC Meeting in person, we ask that you send an email to meetings@asc.gov. You may register until close of business four business days before the Meeting. You will be contacted by the Federal Reserve Law Enforcement Unit on security requirements. You will also be asked to provide a valid government-issued ID before being admitted to the building.

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Another Appraisal Waiver Request

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