No. 64 in Nashville; five in city they  say has shortage 69 total in very short driving distances.

Reasonable suspicion but since the failure will take at least three years to get noticed after they start, its not likely littles are a test case.

I think it is plain old fashioned chutzpah! Hank Paulson got away with orchestrating what was (up til then) the greatest theft of taxpayer funds in history. They see it as a challenge! How much can we get?

Dave Section 1113(b) I think but its easy to look up “FIRREA EVALUATION REQUIREMENTS”

It IS a part of FIRREA and when passed it was never envisioned as a way (right after the S&L crisis) as tool to circumvent the protective measures of FIRREA that have been whittled away at for 30 years.

No one imagined the liars, cheats and thieves of the lending industry would make a concerted effort to say “Screw the taxpayer! S&L? Enron? TARP? You aint seen nothing yet!”

The fact it does not specify commercial means they slip a request in pretending its limited commercial instances affected; when they intend to use it for SFR-2-4-apts-and commercial.

Bank security guard today-eValuator tomorrow! No pesky licenses, training OR oversight. YIPPEEEE!

Well, until only recently nobody was wild and zangy enough to issue billions in loans based on the advisement of their cheetos eating nintendo loving midnight wanking tech crew aka the eval programmers. Boy how times have changed. I would trust wikileaks with my eval long before I’d trust ocwen, I’ll tell you that much.

Let me switch gears for a minute. Today I read about more millions upon hundreds of millions of penalties still ongoing for Ocwen. Time to get out your crystal balls and betting wagers. Do you think Ocwen will pursue waivers and seek aggressive expansion of eval sub programs? What about Wells?

I think focus should be on something less obvious from our side of the desk. Will the use of evals shield these companies from this kind of litigation and record setting liability and legal penalties? Is there a correlation for existing mortgage process abuse penalties that already ties to waivers and sub programs? I can’t help but think there is a bigger play here and the little guys are tasked with testing the water first.

Join the AGA, or your state coalition…or both. We’s a ‘we’!

I call the bowling alley. For real, and I won’t feel bad about getting free cheese sticks or a free lane for an hour. I’ve got to use it to know if the woods are good, it’s all just part of the job. Pass on the no tell’s though, not sure if I’d be able to measure the actual potential income of the dynamic business uses there…  One appraiser in the county does not mean no appraisers available. Someone’s going to break a leg if they keep jumping that far for conclusions.

PS your stats were very revealing. If licensed appraisers are all the way down to 8%, it means all those that didn’t leave are either res or gen certified and or licensed that upgraded to res. certified.

The so called shortage then, is new entrants and lower license, less experience levels (generally), willing to work for peanuts.

I didn’t think we’d drop much below 75,000 this year. Im surprised. At this rate I’m wondering how many will be around in 2019? 65,000?

I wonder if ASC and TAF will announce plans for a new category of recognized ‘valuation’ then. Just above General Certified: “Unlicensed-Unregulated eValuator”…able to appraise anything up to a million. Oil field; agricultural, bowling alley, marina, “no-tell motels”, etc… as long as its in a rural area… or appraisal delays are more than 4 weeks.

Actually I agree with you. My understanding the limits of human nature doesn’t mean I don’t agree with you on this.

Its actually MUCH worse than you indicate now with the recent focused effort for “Snidely Whiplash” style small banks trying to capitalize on the myth of appraisal shortage. It appears they are seeking waivers based on purported commercial appraisal shortage in their immediate area or wait times that are longer than they like – not to mention they want fees commensurate with those they had say around 20 years ago… or lower.

Read VaCAPS post on TriStar Bank; view the webcast they included. Then read the next shoe to drop about the bank in Oklahoma.

While they appear to actually be more affected by limited number of general certified appraisers (not a defined shortage by any measure other than their own) there is no evidence their volume of loans will support another commercial appraiser living in their county. I’m still analyzing that one. I’m not convinced that having to get appraisers from nearby Texas or Kansas IS a hardship or unreasonable.

IF they get the waiver, my understanding from hearing the Tennessee Commission discussing their issue, is that it would also apply to residential loans; and that there is zero regulatory authority (in TN anyway) over FIRREA defined “evaluations.” That means all the niceties and checks and balance requirements of those FIRREA defined evals will go right out the window when they start having bankers that don’t know the difference between a real estate agent/ broker or Realtor(r) “validating” market value.

I have hope Mr. park and ASC will be very, very stingy on granting waivers. Just because Guyon, OK is 457+- miles from OK City (where there is no shortage) does not mean they cant find MUCH closer appraisers in Amarillo or even closer cities in KS or TX.

Waivers are the final straw in the loan related appraisers coffins. They will also be the spark that sets in motion the next national real estate financial collapse.

I’m thinking of switching over to a commission based ice cream truck driver-server. Everybody likes them, and they seem to be paid about the same as we used to get.

I’ll do it for $250 as long as you send me a background check, copies of your concealed carry permit, drivers license, credit card number and pictures of your wife & kids.

Way to go Tennessee !

I appraise in rural Georgia and there is no such thing as “big data”.

The only adjustments I now make are for site value and living area.

Nothing else can be defended. Everything else just gets ignored with a big 0 In the adjustment line.

So nicely said!

2. Tennessee Commission Opposed the waiver and noted its an invitation to commit fraud; rural appraisals are far more complex than urban area appraisals due to limited data. Not the type of complex properties that should be getting LESS expertise rather than more. They also point out (by provision of real numbers) that claim is not as factual as presented. (My words-not theirs). I was thoroughly impressed by the Commission in terms of discussion. One member seemed borderline ‘ready’ to rationalize the banks position but only very tentatively and not with any serious opposition to the rest of the Commission.

3. Tennessee Commission noted they have NO AUTHORITY to regulate evaluations whether signed by licensed appraisers or not. Oddly I cant find a definition for Evaluations in their site; I assume they mean the federal guidelines. All should look those up. THAT IS THE REAL CULPRIT, and threat to appraisers & appraisal integrity to day! I wonder how man other variants we have in states perception of their authority to regulate evaluations, or not. How do you regulates something that has no standards, anyway? 

Ta-Da !! Lessons never learned. What do they care when the industry arses are not effected.

The hits just keep on coming. Let’s pop this bubble with something new, waivers and hybrids. If you’re going to go down in flames, do so in style.

“This bill encourages the finance industry to engage in the type of reckless lending that pulled Americans into a Great Recession – just under a decade ago,” Miles said. “Among its many dangerous provisions, the bill enables poor underwriting, risky mortgages, deceptively steering consumers into overpriced loans, surprise homeowner costs that make defaults more likely and appraisal abuses.”

Dave so now your’re a lawyer too?

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