I’m glad they have “been involved” in 2,000 appraisal defenses since the 1970’s. I have personally performed many times that number of appraisals, since the mid 1980’s.

I have never had an E&O claim made against me. I perform USPAP compliant appraisals.

From an appraisal perspective, none of their suggestions are onerous. They ALL serve MY interests, but I’m not at all sure they solve the problems we just went through. Clearly they benefit insurance companies. But, what about consumers and tax payers?

I understand the motive behind complaint filing fees, but do we want to deprive citizens of due process simply by making it costly for them? We can achieve the same result without attaching fees to complaints, by separate statutes.

The NEXT time some non appraiser regulator decides to come up with appraisal guidelines, I’d strongly suggest they include private fee appraisers with experience in the field, rather than relying on the likes of Andrew Cuomo and his self serving HVCC solution, that has destroyed the appraisal industry.

Additionally, keep FNMA out of the appraisal micro managing business. We already have federal and state regulators. MISMO & UAD add NOTHING to the quality of appraisals. On the contrary, they seriously degrade the entire process.

Mike Ford
CA Gen. Cert. R.E. Appraiser
Former Sr. R.E. Appraiser, U.S. Treasury Dept.

If these thieves who make loans aren’t up to the task of adequately policing their files we shouldn’t empower them further by giving them extend time frames. Additionally, the two year window of time would better serve all concerns with regard to market conditions discernment.

I fully agree with your other two proposals.