If anyone called you girlie in conjunction with any kind of official investigation, you need to file a formal complaint with the Governor and or state auditors office (or A.G.).

If you or I ever did that we would lose our licenses.

Thanks Mike, I still think there is no one protecting appraisers. I didn’t get a fine or an active suspension, but an inactive suspension and have to take a class. But no monetary fine other than having to pay for classes. I just don’t like how they can justify not having appraisal software. Or having to conform to USPAP.

And an inactive suspension means I can work, but not teach for 2 years, so that does affect my livelihood.

The investigator called me “Girlie” in my interview, but that just speaks to his age, not really discrimination.

Amanda, all of what you say may be accurate, but there are two critical things we typically insist on when we try to help appraisers.

BULLET PROOF workfiles, and a review of the issues at hand.

Normally I go over these for hours BEFORE workfile submission deadlines pass. Its too late now. There are reasons we take so much time doing this BEFORE anyone meets with boards.

You are stuck with what you sent them & how you explained it. There is no setting back the clock now. It sounds like you (possibly) got them upset also.

In general NCAB doesn”t have a bad reputation for being unfair. Usually they are deemed moderately easy to work with, but no one will accuse them of being pushovers.

Of course anytime you have a new person trying to show what hes made of, you run risks of over exuberance. I wish we had been involved at the outset.

Having successfully beat California in my own case, I can tell you it costs a small fortune to fight them. Our bill in order to win was $146,000. E&O didn’t come close to covering it for the AMC also involved. Most cases dont cost that much but upward of $50,000 is not uncommon at all.

Im a general Certified appraiser and without undue modesty I’m probably one of the best residential and 1-4 unit appraisers in the country. (In any case I was hired by the Treasury/IRS out of the top 2% in the country). Dont assume that just because we do commercial, that we didn’t also learn how to properly appraise residential, or that we were not also residential sales agents at some point in our careers. Many successful appraisers diversify to keep steady cash flow. C&I is the gravy (high fees); resdiential and 1-4 is the bread and butter that pays the monthly bills.

The guy you got MAY well have been incompetent at res. If so then address those specific deficiencies and not overly broad aspersions.

Either your adjustments were supported by the data visibly evident in the appraisal report itself or they had additional support in your workfile. If you did not pdf it and send it to them, then as hard as it is to accept, the person to be blamed is the person that didn’t follow NC state law. At some level you must have known they were not going to be happy getting data in a format they couldn’t access. When I had my case I had over 690 pages I had to print out from efiles and referenced online sites.

You can usually get by with PDF files, but sending ACI/Clickforms/Alamode/SFREP/ANOW or any other proprietary software was like waving a red flag in front of a bull.

FWIW most states dont have to comply with USPAP. AARO advocates a prosecutorial approach rather than a USPAP compliant appraisal review approach. Frankly Mr. Park and I disagree over this one. States can often do as they will. AARO specializes in going outside legislative channels and TAF panders to that.

Right now as hard as it is, you have to decide to either pay the penalty or fight it. Admin law appeals are very expensive. If you lose then they may well go after your license…and not only a steep fine. Except in extreme cases hiring a lawyer is much more than just paying the fine and biting the bullet. I wish you the best of luck.

If you are interested in seeing how some of them think, here is a link but it wont help with your current situation.

There is an ASC /FHFA meeting on discrimination Friday May 19th, 2023. Its discussing bias. You could register online and offer opinions as a woman owned (that makes you a minority owned) business that states ot following USPAP is another form of bias but that is a stretch and I doubt it would change NCABs conclusions in the least.

As a female owned business owner AND a Latina or Hispanic (IF name is indicative) you MAY have a Hail Mary pass if there is any hint of discrimination or bias in how you were treated. Its a super long shot though.

https://www.eventbrite.com/e/appraisal-subcommittee-hearing-on-appraisal-bias-registration-607544701557

IF you can afford it, it s probably going to be much more economical to pay the fine and take the classes. If its significantly above $5,000 then they are seriously upset with you and you may have to do some soul searching career wise.

I wish I/we could offer more hope and promise but its simply too far into this for us at AGA to be able to help you very much.

Sorry, but that’s a fact. Thank AARO (which should not exist but it does, and it has undue influence with ASC and FHFA).

Its a bias solutions meetings. Five ‘witnesses include one particularly evil entity rep from my State. A State regulator appearing representing the pvt corporation AARO who has had a terrible effect on appraisers. AARO is used o do end runs around legislatures since those state employees cant lobby lawmakers directly outside of channels.

I signed up and am trying to get live mtg attendees in DC area to attend-Late notice.

https://www.eventbrite.com/e/appraisal-subcommittee-hearing-on-appraisal-bias-registration-607544701557

Risk vs reward, minimum standards may not be enough in all situations. Getting reports approved by lenders, their underwriters, and even an amc, may be a different process compared to uspap compliance. On the production side the lenders are just looking for minimum standards, the number, the digital UAD review pass, to originate. On the state and independent legal side is where appraisers may be subjected to the most substantial tests.

Only a decade ago the argument was self contained vs summary report language, appraisers were decrying the notion, considered excessive to provide self contained reporting under amc companies restrictive terms. Self contained approaches are usually in opposition to the notion of outsourcing, discounting, and automation. As one senior appraiser told me which was excellent advice; If something is pertinent to the assignment, make sure it’s in the report.

A collective class action case bringing a Bivens action against HUD and ASC? I think we’re going to need a specific attorney reference and price of service quote on that one. Dare to dream and I’ll sign up as one of many, but not alone. Appraisers are already long since subjected to restraint of trade by these entities, it’s an up hill climb just to even try to stay in business. Could we include REVAA as a defendant now that they’ve chosen to function as industry advisors like some government to themselves? This article is great because it deals with excess sized runaway government, a lot of that going around lately.

Contact Mel Black for guidance. Also Mike Ford with AGA is a good resource for this. ALSO NCPAC maybe able to help