My posted comments to ASC; “I believe many others will comment against this proposed folly. So I will simply ask this; if the waiver is granted please require the requesting bank to formally notify its depositors and shareholders of the action and also compel them to include dissenting views from others including appraisers who have been requesting inclusion onto the banks panel of appraisers for some time. Thank you.”

Appraisal Subcommittee; Notice of Received Request for a Temporary Waiver

Good point Mike

Fritz thats overly broad and inaccurate. I’ve been a staff appraiser. Title company sold our division to one of our marketing people (that I hired) because they were willing to ignore rules (USPAP was brand new) and I wasn’t.

I know many good, even great staff appraisers. We ALL sought staff positions once we were good enough because having predictable income is sometimes a nice luxury. By the way, most staff appraiser positions today have less than a three year life expectancy, so its become much less attractive. Give up your own practice for three years and ten have to rebuilt all over again. Up until HVCC Bank of America Trust Dept. staffers were some of the best in the country. Heck, even FNMA USED TO have good appraisers.

Same here (except for that SRA thingy-I respect yours though).

So JOIN US in fighting against states having ANY discretionary enforcement power of what was originally only federal legislation. With its subsequent rules decided by a private corporation and reinterpreted through an unauthorized entity called AARO whose only claim to fame seems to be as misinformation central and promoting side stepping of USPAP by enforcement agencies.

Mike, I agree. It would be v
Much easier and better for my health if I just walked away from it all. But I worked bery hard for my certification and in the process of becoming and SRA. And I am sick and tired of states getting away with their bullying.

It often takes far more work than one would expect to herd cats. Appraisers are uniquely independent. I think many know in their hearts, a union fighting the battles on a national stage and level instead of state by state is the only eventual solution…BUT we are still catlike in our unwillingness to join a group.

Annemieke, I happen to believe and agree with you about standing behind one’s words but life has also shown me over and over again, that standing up for ones beliefs often comes at a price. I’m willing to pay it, but many (properly) with families to provide for have to keep them in mind first.

So far our legal costs for standing up to California BREA’s outright corruption and deception has cost $142,000+-. Now, my fellow respondents and I agreed that if the state ignorantly wants to force us to take them to Superior Court if they continue to reject the Admin Law Judges Proposed Order exonerating us 100%, we will do so.

But ask yourself-how many appraisers out there are NOT in a position to fight back? The entire system is geared around forcing or coercing consent agreements. Not costly, impartial investigations. People sometimes have good cause to remain anonymous.

Of course they have

No it doesn’t protect the public trust, just like not informing the appraiser of the suspension start date who had to hear it from a ckient and had to have several files reassigned, thereby causing a delay in the borrowers’ loan process.

I heard this board member say it as did a few other people

Yrs we did. And it will happen again. What we shoukd have done is follow Iceland’s example by jailing the bankers and using the money you to help the borrowers.

If you believe in what you stand for you shouldn’t care about who sees your opinions.

I joined and was a member for several years trying to get a chapter going in Oklahoma. No such luck.

5000 – Statements of Policy – Interagency Appraisal and Evaluation Guidelines

Appendix A, appraisal exemptions. For particular individual considerations only, and always use an abundance of caution. Throw that blanket covers all exemption request immediately in the trash can. Look, it’s right there, see for yourself, the exact wording. That request belongs in the trash can.

Understood, Carl. I recall Annamiekes’ name from months if not years ago related to AGA membership solicitation. I don’t think she joined, but I had respect for her loyalty to her own peer association. Like many appraisers, she is her own person – even though in the eyes of others, it may be to her own detriment.

Anniemeke, we all know AMCs and lenders peruse sites like these and some of us are cautious of the possibility of being blacklisted or worse, depending on who we anger.

I respectfully disagree with your comment. Appraisal waivers will create unnecessary and unacceptable risks for taxpayers and homeowners. Didn’t we all bailout the banks not long ago?

PS-If there is any public record of hte Oklahoma Board Chair or any other member identifying themselves as a “hanging judge” then they should be immediately terminated.

Prejudice and bias do not protect the public r preserve the public trust.

I know some of the folks over at ASC read this blog.

You cite yet one more example on top of the half dozen other cases of extreme abuse by regulatory authorities I discussed with them. Not to mention the several dozens more AGA has documented.

States do NOT FOLLOW USPAP in conducting reviews. Many don’t follow their own state laws. Why do states feel that they don’t have to meet minimal acceptable standards required for FRTs? Did they overlook the parts that say even where USPAP isn’t legally required, it SHOULD be voluntarily followed? For Gosh sakes, these are MINIMUM standards, not onerous burdens!

AGA rcentley asked TAF for an invitation to its Investigator I; II, and III training classes in Florida to get a better understanding of how they are instructing state regulators. I’m told its usually reserved for state investigators but sometimes an exception can be made if one is willing to provide an impartial course evaluation.

Just need your home states ok for some unknown reason. Like that will happen! Still waiting on decision. I urge every other coalition or professional peer association to do the same.

Lets find out exactly what they are hiding from the public.It might explain why appraiser investigators like California’s John Schmidt feels its ok to commit perjury under oath, multiple times while on the stand; or why recently (inexplicably) early retired Elizabeth Seaters thought its ok to completely ignore facts and fabricate case “facts” by innuendo rather than actual evidence. (Yes, AB these allegations are matters of public record and I will make the full DVD transcripts available if requested).

Annamieke, The ONLY reason a government employee (appraiser) would be allowed to not keep a work file is that it would be discoverable in court cases -unless you are in California where only the AGs side gets to use subpoenas in ALH hearings.

I’ll be writing more on how administrative hearing laws  across America stack the deck in favor of the state AGs, and how there is NO DESIRE whatsoever among AGs to get to facts or truth. They are only interested in their win-loss score card. That’s a topic for an article all by itself.

The real fault lies with regulators and legislatures that have allowed implementing rules to be written in favor of the state rather than to promote any level of justice.I don’t think they do it purposely. I think it is a systemic flaw that they may be unaware of. A carry over from another era when it was still ok for governmental agencies to abuse the public trust.

Ironic how agencies hiding behind the noble goal of protecting the public or preserving the public trust have to completely disregard the spirit of the U.S. Constitution in doing so. Administrative Law Courts don’t seem to be bound by the Constitution. Who would have guessed?

Annamieke you are not alone in being subjected to ‘slanted’ perceptions, assumptions and prosecutorial ardor. I have many friends that include MAIs, SRAs, ASAs and various other backgrounds that also had consent stips simply because the cost in time and dollars was too great to defend first alleged offenses. None knew that would make them automatically presumed guilty of any second accusations.

BEWARE appraisers-all it takes is one disgruntled seller (or agent) that is not even a client, to set the ball in motion.

Carl, I don’t really care if a bank gets an appraisal waiver. Their money, their sandbox. I am a little curious, however. Why don’t you use your entire name?