ASC, End the Foolishness Now
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Return to a USPAP version (any version) that actually protected the Public Trust. That would be any version PRIOR to the revision of the terms appraisers and appraisals to “valuation & evaluators” (a term used only or at least primarily by the accounting profession historically).
Dissolve The Appraisal Foundation (TAF). They effectively achieved the congressional objective mandated in ’89 long ago. Everything since has been the administrative equivalent of ‘word smithing’ without good cause. Aside from trying to justify their existence.
Since (circa) 2009, TAF has made it ‘easier for regulators’; and created unnecessary bars to new appraisers joining the profession. Mainly so they could create a shortage and then cry “Whoa is me, we must do something to bring new people in.” Hence PAREA.
They missed the problem by 180 degrees. It’s the ridiculous degree requirement blocking entry. Not the experience requirements and training. Some elitists contend we cannot be a ‘profession’ unless we are all degreed.
If that is the only concern, then let’s end the pretense right now. I contend we are professionals because of our extensive experience, subject matter education specific to our professions, ongoing educational requirements, and our commitment to ethical professional practices.
Some of the best appraisers (trainees and long time appraisers) I ever encountered lacked college degrees. Some of the highest credentialled appraisers (both designated and those undesignated but with advanced degrees) were among the worst appraisers I’ve ever encountered. Many engineers for example have a terrible time dealing with the ‘art’ side of real estate appraisal. That’s aside from some degreed individuals being ethically challenged as well when enough money is involved. Those student loans won’t pay for themselves…yet, anyway.
I’m non-degreed, but the federal government in its infinite wisdom saw fit to certify me qualified at GS grades ranging from GS-12 to GS-14; & hired me (’09) at the GS-13 “Engineer” level (a grade above that divisions own attorneys). It was based on skill, experience primarily, and education secondarily. Experience in the profession was counted as two years is equal to one year of advanced education. That particular department was The Treasury Department, Internal Revenue Service, Large Business & International Division, as a Senior Real Estate Appraiser.
It wasn’t a fluke. HUD certified me (GS-14); VA (GS-12) GSA (GS-13), Dept of the Navy (GS-12 & GS-13) & Army Corps of Engineers (GS-12 – real estate management, not appraising).
My point isn’t to be boastful. It’s that ALL experienced appraisers have the ability to become top professionals in our field.
As long as they adhere to professional principles and ethics; continue to learn, earn and retain a high level of public trust (real trust – not the TAF or states lip service “Trust”) and have the ability to pass such appraisal tests as currently exist across the country.
Every five to ten years, representatives from Professional Peer Associations; Guilds, Unions, & State Coalitions could meet to decide IF and WHAT changes to USPAP may be required. We could do it a lot cheaper than TAF does too!
There would NOT be any ‘stakeholders’ or lobbyists represented at such meetings. Appraisal PRINCIPLES are foundational. They don’t change. Permissible practices MAY change based upon the collective wisdom of the profession. NOT the dictates of one (albeit large) segment of appraiser users.
Too many of our ‘Rules’ are outgrowths of convenience for non users of appraisals (like regulators); or responses to pleas for cheaper and faster products dressed up like real appraisals that can be performed in 1/10th the time required for a good appraisal. Or, done for three peanuts and a banana in lieu of a reasonable fee commensurate with the professional work being requested.
Mortgage Companies and banks are not the only users of appraisals. Individual investors that DO care how their money is invested because they have no government backing; or attorneys and courts, or state and federal agencies (unrelated to finance) all use appraisals. As do consumers in order to protect themselves from predation by unscrupulous loan officers and banks.
As TAF obtains more and more of its gravy, er operating capital, from vested parties that USPAP was intended to protect the public from, the public trust is eroded more each day. So too is the trust appraisers once held in TAF and our own standards.
Terminate TAF’s ‘authority’. Let ASC establish a minimalist framework for education and enforcement that is consistent across the country in the form of federal rather than state appraisal laws.
End the constant ‘busy work’ USPAP updates. End the catering to lenders or ‘advisory’ councils. Appraisers are NOT supposed to be any of the things being demanded of us today EXCEPT good appraisers!
The technology-fixes-everything whores that keep popping up and interfering with real appraisal can stick with election ballot counting or polling or other forms of marketing that they are so esteemed for. They have no business telling appraisers OR the public that their new whizzbang product is “just as good” as a real appraisal.
ASC, End the foolishness now. Federalize appraisal regulation and enforcement.