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.

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.

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.

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!

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.

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

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. 🙂

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!

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.

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.

LICENSED IN 15 STATES!?

Credibility; Denied.

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.

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

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:

http://www.millersamuel.com/sadly-the-appraisal-institute-is-now-working-against-its-local-chapters/

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.

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.

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!!!“

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!

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.

https://www.gpo.gov/fdsys/pkg/FR-2015-06-09/pdf/2015-12719.pdf

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?