Thank you !!! I have been saying that for years !!!

There is no bright side. We’re damned if we do and damned if we don’t. Be a number hitter or else be blacklisted and lose business. The smart ones retired. I can’t wait to retire next year!

Two main thoughts arise for me on reading your article. (1) The liability is understated. It is the broad liability itself that is now used as semi overt pressure by lenders such as Wells Fargo, Chase and  several others through their AMC agents. Come in low and decline to be persuaded to raise a value based on their hand picked comparable and you’ll will find your self answering to the state board for some unrelated technical issue in your report.

(2) At least 25% of states have already proven they don’t understand practical application of USPAP requirements.This was proven by Oregon’s admission that they were coercing settlements  of purported USPAP violation for late appraisal delivery. This view was still held despite TAF/ASB publishing an Advisory Opinion that late delivery has nothing to do with USPAP. Did Oregon learn? Of course not! Their response is that the issue is not settled until it is decided by an Administrative Law Judge.

Think about that one. The people that write USPAP may not explain its intended legal application unless an Admin Law Judge (hired by the very agency that misrepresented USPAP in the first place) agrees with them!

With 1 in 4 to 1 in 5 states NOT understanding USPAP appraisers are like Sisyphus trying to push that boulder up the mountain side. No matter how hard they try to do their tasks, the risk of being crushed by the weight of special interests and incompetent, complicit  regulators will always be there.

It’s really time to take another look at FIRREA. IF it is Congress intent to strip away virtually all systemic collateral protections then lets just admit it. Eliminate regulations, licences, uniform standards and let appraisers have the same freedom to guess at values that an AVM does. Just call the appraisers future uncontrolled wild west methods “Long Experience” vs the AVM “Big Data”. Clearly with the right euphemism any ‘new method’ must be ok!

Of course the results will be unreliable, but at least it will be a level playing field- absent the pretense