Lack of individual persons having licensing means it’s simply both time and cost prohibitive to regulate an amc. Because the amc is a corporation, not an individual.

I think the industry missed the mark on effective regulation by defining type rather than action. This industry should have regulated all aspects of ‘managing and engaging’ appraisers, rather than defining a specific business model type. Because they’re not licensed, mortgage persons can use them to levy tremendous pressure on licensed appraisers, effectively firewalling themselves behind non licensed individuals. With evals coming into the picture, expect more of the same.

I’m quite sure this industry has lost around 80% to 90% of the available full fee direct assignment order streams we enjoyed a brief 10 years ago.

True. Now what ASB does NOT do is include any requirement that MY state regulators (Sr. Real Property Appraiser/Investigators) follow USPAP SR3 & SR4 in their analysis of an appraisers ‘factual’ compliance with USPAP, state law and federal regulations.

TAF wanted to straddle the fence and they have done so admirably.

GUIDANCE

The ASB issues guidance in the form of Advisory Opinions, USPAP Frequently Asked Questions (FAQ) and periodic questions and responses “USPAP Q&A.” These communications do not establish new Standards or interpret existing Standards and are not part of USPAP. They illustrate the applicability of Standards in specific situations and offer advice from the ASB for the resolution of specific appraisal issues and problems. Please note that the “See also FAQs” references shown in the margins of the Standards are in addition to already footnoted Advisory Opinions (AOs); the location of these references do not place greater importance of USPAP FAQs over AOs, they are simply another reference tool for the users of USPAP.

AOs are not enforceable, nor are they USPAP, per USPAP PAGE I.

Mr. Apa, interesting (& appropriate) perspective comparing burger flippers with “evaluators”. I suspect the burger flippers have higher mandatory standards since they have to comply with meaningful health and safety codes. While unlicensed ‘appraisers’ have none, and interagency ‘guidelines’ are set up to assure plausible deniability rather than enforceable standards.

“Legitimized;” by whom and in what way? Like a BPO?

As for being better to have an appraiser doing evals; in California, they are no longer ‘evals’ if an appraiser does them. They are appraisals. They’d have to conform to USPAP.

Under FIRREA evals may NOT be called an appraisal. It’s a Catch 22. If they are appraisals, then they are no longer evals.

I don’t doubt there are a lot of lost their license former appraisers doing them in mandatory USPAP states; which contrary to logic-allow unregulated unlicensed ‘appraisers’ to operate (again-California as an example). “The financial system” doesn’t need appraisers doing evals. It WANTS appraisers doing them. If only to lend a sense of credibility to what is otherwise a pure garbage product.

When banks got evals written into FIRREA I’m sure they told Congress they were only done by informed branch managers or local brokers. Yet they insisted on final language that allowed the parking lot attendant at the bank, a secretary, clerk, butcher, baker and any other nincompoop willing to work for chump change to do them.

The Job opportunity already exist for Licensed Appraisers. USPAP AO-13 is very clear and explains the responsibility of a Licensed Appraiser when it comes to evaluations in the context of inter-agency guidelines. This is all about shifting Blame for the Next Bail-Out! Just My ever so humble opinion.

When are state boards going to start “supervising” AMCs, which is part of their minimum requirement for taking registration fees.

Your efforts are greatly appreciated.

As far as State Boards, especially those loaded with AMC employees.

So much for “public trust” when there aren’t any written Uniformed Standards for evaluations.

Dustin, is that you?

Seek the truth.

LOL! So proud you’re hiding behind a fake name. Thanks for the laugh

Mr. Ford: Enjoy your time in irrelevance. Like it or not, the banking world is going the way of evaluations. Evaluations are already legitimized and have been since the 1990’s. I’d rather be doing evals. than flipping burgers. I know of colleagues that make a killing doing commercial evals. Aren’t you more qualified to do an eval. than some nincompoop off the street? The financial system needs appraisers doing evals. rather than butcher, the baker and the bartender. It’s better for the public trust. Do you really want A.O.C. doing evals.?