Such a central portal for fnma work was proposed in the IVPI proposal. Care to revisit that yet?

I swear to you, this is the most important shock document you can send a non appraiser.

Reading it a decade later is much more hard hitting than dealing with it at the time in 2008 era.

Hindsight is 20/20 and dang, most ‘reforms’ resulted in even more god awful unethical behavior than could have even been predicted. The work towards effective solutions was completed some time ago, no additional work is needed other than to institute these amazing process approach ideas.

http://www.workingre.com/wp-content/uploads/2013/08/IVPI-Proposalfinal.pdf

Banks Shutter 1,700 Branches in Fastest Decline on Record

Profits at record levels. Banks are having a hard time finding quality help, because they refuse to pay regular employees and would rather keep it all as corporate executive profit. Reasons why I refuse to bank online, I like having a local branch available and make sure I am one of those regular foot traffic people.

3. What possible legal; and beneficial reason can exist for AARO to become so cozy with AMCs and their lobbying organization? When something stinks, it is usually because it is rotten-like that relationship. REVAA has a right to seek favorable legislation. With elected LEGISLATORS, NOT salaried bureaucrats charged with enforcement!

Because state regulatory (enforcement) authorities are not allowed by law (in most states) to actively lobby to change the laws they operate under, they created AARO.

It had the potential to be a good thing, but as operated it is just the opposite.

1. It allows TAF and state enforcers to completely circumvent any laws or legislative limitations that they find ‘inconvenient’.For example, requiring USPAP compliance BY states when investigating alleged violations of USPAP is not considered ‘necessary’.

2. When one state misinterprets USPAP, then the ignorance is shared & promoted with all the others.

3. What possible legal; and beneficial reason can exist for AARO to become so cozy with AMCs and their lobbying organization? When something stinks, it is usually because it is rotten-like that relationship. REVAA has a right to seek favorable legislation. With elected LEGISLATORS, NOT salaried bureaucrats charged with enforcement!

4. Who doesn’t like a free weekend get away at taxpayers expense? I used to love the road trips when I worked for the Feds. Then at years end when the budget was gone, magically we were able to accomplish the same and more by using Citrx Go to Meeting or similar online services.

5. Look at AAROs name. Now look at the above breakdown of attendees. Everyone of these attendees including the regulators, should be getting their direction from their state and federal legislators via well written law. Not lobbyists. There is a difference between appraisers, our organizations and even AMCs attending just to monitor AARO; as opposed to sponsoring parties to push agendas.  AARO serves no valid beneficial purpose for either state enforcement officers, taxpayers, AMCs, professional organizations or appraisers. It should not have the blessing, endorsement or support of any state or federal agency.

TAF can do what they want. They are becoming increasingly irrelevant.

A lot apparently. Its a really BIG dog!

Although the parasites are killing it. Its not in the nature of parasites to think about preserving their hosts. When one gets too sick to support them, they can always just jump off and find another.

How many parasites can this dog of an occupation support?

AMC’s are a true problem for our existence – http://www.AARO.net not doing their jobs EVER is the true reason for this problem.

Why is AARO a problem? Note who the attendees were for the spring 2017 conference (AMC’s outnumbered even the regulators themselves) – There were approximately 70 attendees for the session. The breakdown of the number of attendees was approximately 20 (out of 50) State Regulators, 24 AMCs throwing free parties and dinners of which Appraisers were not welcomed, 8 Education Providers, 6 Professional Organization representatives, and 12 Appraisers (there were a few more at the Fall Conference in DC)  and other attendees.

This event should be renamed the http://www.REVAA.org Conference as they truly are running the show at this time.

Jack your scenario and story are painfully too familiar top all of us. I’m sorry about your loss of 90% of work due to undercutting. Its one of those 20/20 hindsight lessons for all appraisers. Under no circumstances put your entire livelihood in the hands of any one client – whether an AMC or direct lender.

For those in markets where you either work with AMCs or don’t eat – I strongly recommend at least three AMCs until you can diversify to non lending work. With AMCs it isn’t a case of IF they seek lower fees and cut you off, but when.

I think VaCAP (& Virginia) have done great work but the time to keep trying to fight these issues on a state by state basis has passed us all by. Virginia, North Carolina & Louisiana to my knowledge are the only ones that ever passed any meaningful C&R fee or other beneficial appraiser/ consumer appraisal laws.

Oklahoma is considering repealing its AMC license and registration laws because of the burden (costs) of administering them. Many other states like my own (California) can’t be bothered with enforcement of Dodd Frank. Strange how the Congress Member whose former committee was so supportive of DF won’t even pass enforcement mechanisms for it at the state level.

Jack that by the way is our entire problem in a nutshell. States either cannot or will not uniformly enforce ANY appraisal laws, including FIRREA.

It is why we must move on to the next stage of the regulatory battle – taking it away from the states (for FRTs anyway) and putting it directly back in the hands of the Feds. One agency for monitoring compliance, and the same agency for enforcement of punitive actions when necessary. My suggestion is the ASC.

Going into the future, each states coalition; & AGA, & existing professional peer appraisal organizations would have only one point required to submit ideas for needed changes. A focal point where all appraiser groups could be registered as information contacts; OR the system could be set to notify us individually via emails. ASC has the ability to collectively inform members of the FFIEC on all issues.

Its not like appraisers aren’t already registered with ASC.

Just my opinion but I believe wishing that Fannie and Freddie set fees and rules for appraisers could be an indication of the Stockholm Syndrome. For those that have forgotten, the Stockholm Syndrome is a condition that causes hostages to develop a psychological alliance with their captors as a survival strategy during captivity.

Has everyone forgotten who some of the players are that have created much of the misery that appraisers now deal with?

That is so kind of you Juliana. As for Congress, probably not. Circa 1986-1990 I did my political activism in a small city of 150,000 (in Redondo Beach; L.A. Times; Daily Breeze and Easy reader for background). Its an all consuming, dirty behind the scenes process that leaves almost no time for anything else. If successful it would make me one of ‘them’ rather than an ‘us’.

I think there are other, smarter folks for  that. My commitment is to my profession; my peers and our appraisers Guild.

Well put Scott R.

I agree in wishing that Fannie & Freddie had a portal and set fee’s such as the VA does. With the VA, we have a relatively clear set of rules to follow. When completing an appraisal report for the VA if we cross our T’s and dot our I’s, the lender/underwriter typically has no say in the matter.

The way the current AMC model works appraisers have literally hundred’s of variations regarding the playbook we have to follow, including USPAP.

AMC’s, lender’s, underwriter’s, etc., often seem to make things up simply to justify their existence.

When I do an appraisal report for a private client such as an attorney or accountant, I have a clear set of rules to follow, USPAP.

When I do an appraisal report for the VA, I follow USPAP and the VA Handbook.

When an AMC orders an appraisal report……it’s a free for all more often than not that might require days worth of revisions that are unpaid to the appraiser.

No thank you AMC’s.

I sincerely appreciate the concern and the viewpoint Olivia.

Lets not confuse ‘geographic competency’ as being any different than competency. The latter, requires the former.

If states surrendered implementation of federal law (FIRREA) to the feds, it isn’t going to result in hoards of people jumping state borders to chase work (more than already happens). Every single one of us is required to perform our work competently.

I would imagine that if you chose to do so, you could familiarize yourself with parts of the Missouri market and go there under a federal license…but you already can do that with a reciprocal license. I live right next to a county line and while I will do work even farther away, I generally avoid that particular county simply because I don’t like how pubic records are maintained for living area. Who needs the extra burdens?

The mechanics are flexible; no one person can have all the ‘only’ ideas. Reaching out and trying to consider and address all appraiser concerns like your own is a first step. I hope you and others will think of this in terms of seeking viable national solutions to inconsistent application of federal law.

Or, we can keep fighting every single issue on a state level 50 times over; and be over taken by new abuses and threats before we can ever achieve 50 individual solutions in 50 states.

What is clear, is that most states cannot competently and consistently enforce USPAP in a uniform manner.

Some states did not, and still do not have real estate appraisers on their enforcement panels! That’s why we get states like Oregon telling appraisers they are in violation of USPAP simply for reports delivered late…and who then argue that “well we checked with 11 other states and hey all agreed we were right.” These are not isolated cases of state ignorance or less than effective enforcement.

As for federal enforcement, I wasn’t very detailed (yet). The reason for that is solutions have to be developed by consensus, not dictate.

Any specific proposals would have to include AI, ASA, NAIFA (& all the others that are equally important); coalitions, guild and individual appraisers across the country. There is tentative willingness to seek solutions of this type expressed by members & or leadership of each of the above.

Tentatively envisioned is a LOCAL volunteer panel in each state to handle the actual analyses of any complaints. The panels would (optimally) be drawn from your local professional organizations (all); your state coalitions, & the Guild.

No single reviewer decision makers – majority would have to concur that something is substantial and significant to results in context of intended use before a serious USPAP violation would be opined. No “gotchas” for not dotting an ‘i’ or crossing a ‘t’.

Integrity related issues would be escalated immediately to more specialized reviewers. Procedural issues would be handled by appraisers familiar with those types of property – not state employee ‘generalists’ that have not performed an appraisal in 20 years.

I’m not thinking of three or five member state panels either – but a pool of pre qualified reviewers that could include as many as fifty to a hundred panelists. It would take a large group of volunteers to cover all areas and residential, apartments, commercial, industrial, agricultural etc..

Big state could possibly have many smaller ‘pods’ of reviewers in all urban areas; and draw from outlying areas as well.

Initial screening by small group to see if there appears to be cause to investigate beyond a cursory review for dismissal. Possibly limiting complaints to clients and intended users; or at least limiting review to specific issues raised by non client complainants – not using complaints for witch hunts.

Issues that COULD be solved by default if we revert to federal oversight are:

1. Reduced fees. States are now increasing fees to make up lost revenue from fewer licensees. Could be as low as the Federal component of our fee is now;

2. AMC pressure. Single FEDERAL point to report AMC violations of AIR to versus the confusing poorly defined or identified authorities in place now.

3. Fees; deminimus fee level COULD be established at VA rate or similar government study – eliminating need to fight this war in every single state

4. It’s unlikely FTC and other lobbied federal agencies would frivolously sue ASC for enforcing federal laws.

5. It’s not necessary to have USPAP rewritten every two years. That is purely for the ongoing benefit of TAF.

6. Eliminate private agency (TAF) development of implementing rules for federal laws. They already finished their jobs as mandated under Title XI

7. Eliminate private agency (TAF) coordinating political agendas with state officials through AARO thus circumventing individual state legislatures will and bypassing laws prohibiting public officials from engaging in political advocacy.

TAF & AARO both now set enforcement policies. Only TAF was ever established by Congress… and they have gone far astray of their mandate.

8. Eliminate all non real estate appraiser disciplines from boards setting R.E. Appraiser policies and guidelines; or AQB requirements. Did you know that previously we had a foreign national business valuator with offices in Mexico City as a TAF board appointee voting on real estate appraisal issues on her board? (Smart, nice lady but what business did she have helping set R.E. Appraiser practices?)

9. Perhaps most significantly, having a single point of appeal that has uniform standards for appeals. Many states have Admin Law Courts, but even if you win as an accused, they don’t have to accept the judges decision! Don’t even think of trying to represent yourself. Volunteer panels could be less formal – applying common sense over formalities too technical for most of us to navigate without costly attorney fees.

10 Several states have proven high levels of corruption if the administration of their appraiser licensing laws. In some cases it is having board members that are direct competitors to those they investigate; in others it is a good ol’ boy network; and in others it is adoption of policies to coerce settlements rather than to impartially investigate complaints.

11. Some states (California) have already announced they are raising fees to make up for loss of license revenue. Many larger states are left with similar short falls and would actually save a lot of money if they no longer had USPAP compliance obligations. Many (if not most) states have already abandoned the practice of having field reviews for value complaints. I doubt any here want to be second guessed by a hybrid style review. It also appears TAF, & AARO are advocating that it is unnecessary for enforcement reviews to be USPAP compliant themselves. (Do as we say, not as we do?)

Some larger states have backlogs of 500 or even 600 complaints with less than a dozen investigators, doing as little as 2 to 3 cases a month. Do the math. They will never catch up; hence the pressure to coerce settlements.

These are just some of the issues. Right now very few AMCs worry about state enforcement of any issues because they know the state laws are weak and unclear. Faced with federal enforcement by people that potentially have access to their tax records, or that are less susceptible to issue mischaracterization – I think we’d see AMCs AND mortgage brokers cleaning up their acts a lot.

Olivia, I sincerely appreciate your input and hope you will continue to offer more ideas and views, whether in agreement or disagreement.

Interesting HUD article Baggs. Thank you. Road to hell is paved with good intentions kind of thing from HUD? As usual we were either an afterthought or a never-given-a-thought line entry.

I’m licensed as a certified residential appraiser in 2 states (I’m in the Kansas City Metro) and I disagree. I think having state control over appraisers is actually a good thing. What we do is so dependent on geography and market specific that it is imperative the people policing us have similar geographic competence.

What I would be thrilled with is Fannie and Freddie having a portal and system like the VA does. Set fees. Set rules. Set turn around times. We can talk to the LO, but are assured independence by the governing body (VA).

FYI, That’s the RESPA 590 page regulatory impact analysis, circa 2003 I believe.  When I first started I used to read through everything I could find.  Oh, the memories, dreaming of tangible success in my near future. Clearly I underestimated the power of middle management to swindle futurity.