Done!

Admn, Could you drop that picture please? Thank you.

Great. Good job Francois.

Check your email for contact information. It looks like we got the result we wanted from the FREAB.

Retroactive accountability? That’s never going to happen for the majority of us. I find it detestable that the worst appraisers who worked for amc’s are getting access to class action and the wise appraisers whom refused to go so low are not represented in similar fashions. Lawyers, always chasing the deep pockets so hopefully perhaps some correction will occur. Wake me when fee and turn times are not the predominant factor in distribution trends. Amc or not, it does not matter, virtually all distributors treat appraisers like employees. If you don’t comply, you lose access to work virtually immediately. If I could claim retro billing for overtime, I should be able to capture about 10 years worth of underpay and overtime wage from about 300 different companies. Never going to happen.

Hi Gregoire, It’s an excellent letter. It may have too much in it for them to consider though. You pretty much have to lead regulators by the hand.

In the end I think we are all going to have to insist that one single federal agency be responsible for setting ALL FRT appraisal policies in America. That would have to include USPAP and all license enforcement.

Florida’s example is yet another of the Heinz 57 Flavors of regulations appraisers are going to be expected to follow. States that already are incapable of uniform USPAP enforcement now won’t be able to tell the difference between an evaluation and any of the so called hybrids that DO call themselves appraisals.

The dumbest thing Feds; TAF and all the other appraisal organizations ever did was to pretend calling an appraisal by another name (Evaluation) made it an exception to USPAP somehow.

Florida wrongly thinks that declaring an evaluation is not an appraisal it will somehow clarify anything. It won’t. Those that want to side step USPAP and reasonable fees will just give “valuations” a proprietary name such as “ClearVal Appraisal”, and sidestep Florida regulations by saying they are conforming to Federal guidelines.

Wouldn’t it be nice if we had ONE set of appraisal guidelines, principles and standards for all appraisers in America that was uniformly interpreted and enforced? Something written by and interpreted only by other appraisers? Something where ‘principles’ were treated as a core foundation rather than dirty underwear that has to be changed on a regular basis?

Just an idea, but maybe we could call it The Uniform Standards of Professional Appraisal Practices? You know, a derivative of the old AI / SREA principles and practices that predated FIRREA.

I’ll send separate PM to inquire how we can help your efforts.

Jeff, I think you just got the word out.

Each appraiser has to decide for themselves whether or not they want to be an inadequately compensated employee of Mercury or any other AMC that sets their hours for them.

There are attorneys all across the country just chomping at the bit to file labor law suits against these jokers. Additionally, I understand state and federal tax authorities may have an interest due to inadequate withholding of necessary sums for employees.

Just calling someone an independent contractor is no longer enough. They must actually BE independent contractors. AMCs set the fees under TRID. All pretenses to the contrary have been disproven. AMCS set the due dates and impose penalties if they are not met. Now, if AMCS also schedule the appointments controlling the appraisers working hours I think we will see a lot more litigation.

Appraisers have been suing for overtime and getting it retroactively dating back many years. Thank you Landsafe; Solidifi and any others of that ilk.

Thank you Francois. A very excellent letter. Recommended reading. Force evals under the regulatory umbrella. Now, how can we force distributors raking hundreds of millions a year to comply with ethic? I say force all of them to be licensed with appraisers licenses for matching congruent rule application. Amc’s are powerhouses whom wield more influence than all of the licensed individuals combined. The time to regulate the workers individually is also now. The technical people are running the show, completely unlicensed, completely unaccountable, redirecting the billions of earnings of an entire industry into a select few pockets. If the distribution industry needs technical specialists, those specialists must also carry valid appraisers licenses.

Like many other efforts and technical approaches, Mercury could favor the appraiser, but they consistently as a rule of thumb, advocate for lenders first. They could have our schedule online the lenders could comply with, but do not. They could disclose fees, but do not. They could offer options to avoid all broadcast orders, but do not. Mercury consistently positions as an advocate for the lenders interests. They wont’ inform clients how many orders appraisers have, that might bring fair balance to distribution. The lady told me they are just a technical servicing company and ethical concerns are not their concerns. They don’t work weekends. Whatever the technical staff dreams up becomes the ethical future for appraisers, mind you they are not bound by ethics what so ever.

Mike this is off the subject but a new and important subject. AMC’s and Mercury Network are now trying to schedule appraisers inspections for them. Can we put a stop to this and get the word out that appraisers are not going to tolerate this. The AMC will ask the borrower for 4 available dates which will work for them. What they do not realize is that as we have to travel in larger counties that we typically schedule multiple appraisals at the same time and this idea is not thought out and just an attempt to move the appraiser to an employee. I get so mad at this crap

Links to the FREAB Agenda and additional documents are posted on Appraiser Active. Hint: Take a long look at the USPAP Ethics Rule.

Thanks!

Corrected. If you see anything else, let us know.