The Appraisal Waiver Avalanche
The State of North Dakota Along With Their Banking Lobby, Applies For a Waiver
This just came in so I will expand on this post in the future, but here is what we know.
The governor has submitted a request to the Appraisal Subcommittee for an appraisal waiver but the letter seems more orientated towards raising the de minimus which just occurred. By the way, isn’t it apparent that the banking lobby is a little to cozy with the Governor’s office to actually cosign this letter? The letter also makes references to the lack of rural appraisers as a long-term problem.
It is also clear from this letter that the FDIC hates appraisers (I have seen this for most of my career) as they facilitated the eventual writing of this request.
The key problem with this request is that the number of credentialed appraisers in North Dakota is up sharply from 2007 to 2017. Here are the numbers:
- Licensed residential is up 62%
- Certified general is up 50%.
- Certified residential is up 8200% (only because there was no such category in 2007).
Regarding the long-term narrative about a shortage of rural appraisers and removing their requirement to follow USPAP, ask yourself these questions: would the same apply to medical licenses for doctors and dentists; passing the bar exam for lawyers; licensing and training for food service inspectors when availability is thin due to the economics of rural life? Why aren’t rural appraisers allowed to participate in supply and demand like doctors and dentists, lawyers and food service inspectors? How about the fracking companies that pay $150,000 for 6 months for an employee because labor is scarce? The problem here is this waiver will promote bad behavior no matter how well the state did in the aftermath of the housing bubble.
Interestingly the licensed category in 2007 was exempt from AQB requirements and that didn’t go well for North Dakota.
Be sure to read their letter.
Here is the North Dakota waiver letter.