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	Comments on: Hybrids vs USPAP Scope of Work Rule	</title>
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		<title>
		By: Mike Ford, American Guild of Appraisers		</title>
		<link>https://appraisersblogs.com/bifurcated-appraisal-vs-uspap-scope-of-work-rule-sow/#comment-27824</link>

		<dc:creator><![CDATA[Mike Ford, American Guild of Appraisers]]></dc:creator>
		<pubDate>Wed, 18 Sep 2019 02:17:24 +0000</pubDate>
		<guid isPermaLink="false">http://appraisersblogs.com/?p=22485#comment-27824</guid>

					<description><![CDATA[In reply to &lt;a href=&quot;https://appraisersblogs.com/bifurcated-appraisal-vs-uspap-scope-of-work-rule-sow/#comment-27822&quot;&gt;Joyce Potts, SRA, AI-RRS&lt;/a&gt;.

Joyce the samples of hybrids we have seen makes hybrids considerably different than a drive-by. In a driveby, WE have viewed the subject and its neighborhood as well as locational influences of the comps.

We are not (default text embedded in those piles of pony loaf) &quot;Deeming&quot; the inspection to have been competent when we have no control or even contact with the inspector-nor any idea of their qualifications or personal integrity.

IF promoters of these would quit pretending that the fundamental format is &#039;USPAP compliant&#039; instead of using or relying on sophist claims that it is not the form but the appraiser that determines compliance. These forms LIMIT appraiser input despite disclaimers that nothing prevents an appraiser from adding such additional information as they deem to be required. The entire form and format is based on lies, deception and misdirection.

Stop calling them appraisals or claiming they are USPAP compliant and I&#039;d have no more argument with them than I would an AVM. One typical poster child example of such bifurcated-crapfest is right here in AB http://appraisersblogs.com/clearval-value-hybrid-appraisal]]></description>
			<content:encoded><![CDATA[<p>In reply to <a target="_blank" href="https://appraisersblogs.com/bifurcated-appraisal-vs-uspap-scope-of-work-rule-sow/#comment-27822">Joyce Potts, SRA, AI-RRS</a>.</p>
<p>Joyce the samples of hybrids we have seen makes hybrids considerably different than a drive-by. In a driveby, WE have viewed the subject and its neighborhood as well as locational influences of the comps.</p>
<p>We are not (default text embedded in those piles of pony loaf) &#8220;Deeming&#8221; the inspection to have been competent when we have no control or even contact with the inspector-nor any idea of their qualifications or personal integrity.</p>
<p>IF promoters of these would quit pretending that the fundamental format is &#8216;USPAP compliant&#8217; instead of using or relying on sophist claims that it is not the form but the appraiser that determines compliance. These forms LIMIT appraiser input despite disclaimers that nothing prevents an appraiser from adding such additional information as they deem to be required. The entire form and format is based on lies, deception and misdirection.</p>
<p>Stop calling them appraisals or claiming they are USPAP compliant and I&#8217;d have no more argument with them than I would an AVM. One typical poster child example of such bifurcated-crapfest is right here in AB <a target="_blank" href="http://appraisersblogs.com/clearval-value-hybrid-appraisal" rel="ugc">http://appraisersblogs.com/clearval-value-hybrid-appraisal</a></p>
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		<title>
		By: Bill Johnson		</title>
		<link>https://appraisersblogs.com/bifurcated-appraisal-vs-uspap-scope-of-work-rule-sow/#comment-27823</link>

		<dc:creator><![CDATA[Bill Johnson]]></dc:creator>
		<pubDate>Wed, 18 Sep 2019 00:45:36 +0000</pubDate>
		<guid isPermaLink="false">http://appraisersblogs.com/?p=22485#comment-27823</guid>

					<description><![CDATA[In reply to &lt;a href=&quot;https://appraisersblogs.com/bifurcated-appraisal-vs-uspap-scope-of-work-rule-sow/#comment-27822&quot;&gt;Joyce Potts, SRA, AI-RRS&lt;/a&gt;.

I often spend a good 30 minutes to an hour looking into a property and the available market data before taking an assignment Joyce, and I would suggest others do the same. 

Why would the current MLS listing characteristics vary from public record files? Why does the current listing vary from past MLS listings? Are there new building permits on file? What is the current zoning, and is it legal? Has the subject sold in the past 3 years, was it a flip? Has it increased or decreased in value and if so is it inline with the greater market? Has the property been refinanced in recent years thus a UAD file would be on record? If you use A la mode, does the subject show up as being used by a panel of your peers, and does your initial opinion vary from theirs? Etc. etc. etc.

Only after knowing the above and more, and then comparing that set of data points to the greater market area can one determine the complexity, time needed to complete, a reasonable fee, liability, and if you want to do the assignment at all.

Joyce, do you really think a soccer mom with a few hours of training doing an inspection from the street is on par with a trained appraiser? Why did I spend an hour today walking a 500+ unit condo development spread over huge acreage? Because the sales prices vary for a reason. Where were the sales specifically located? Did they face the parking lot, the dumpster, the courtyard, or the canyon? Did they truly have a view, or were the agents lying? Do all of the downstairs units have larger patios with yards? How big were the 2nd story balconies in comparison to the 1st floor patios? 

The idea that you see little to now difference relating to who does the inspection is scary.   

Seek the truth.]]></description>
			<content:encoded><![CDATA[<p>In reply to <a target="_blank" href="https://appraisersblogs.com/bifurcated-appraisal-vs-uspap-scope-of-work-rule-sow/#comment-27822">Joyce Potts, SRA, AI-RRS</a>.</p>
<p>I often spend a good 30 minutes to an hour looking into a property and the available market data before taking an assignment Joyce, and I would suggest others do the same. </p>
<p>Why would the current MLS listing characteristics vary from public record files? Why does the current listing vary from past MLS listings? Are there new building permits on file? What is the current zoning, and is it legal? Has the subject sold in the past 3 years, was it a flip? Has it increased or decreased in value and if so is it inline with the greater market? Has the property been refinanced in recent years thus a UAD file would be on record? If you use A la mode, does the subject show up as being used by a panel of your peers, and does your initial opinion vary from theirs? Etc. etc. etc.</p>
<p>Only after knowing the above and more, and then comparing that set of data points to the greater market area can one determine the complexity, time needed to complete, a reasonable fee, liability, and if you want to do the assignment at all.</p>
<p>Joyce, do you really think a soccer mom with a few hours of training doing an inspection from the street is on par with a trained appraiser? Why did I spend an hour today walking a 500+ unit condo development spread over huge acreage? Because the sales prices vary for a reason. Where were the sales specifically located? Did they face the parking lot, the dumpster, the courtyard, or the canyon? Did they truly have a view, or were the agents lying? Do all of the downstairs units have larger patios with yards? How big were the 2nd story balconies in comparison to the 1st floor patios? </p>
<p>The idea that you see little to now difference relating to who does the inspection is scary.   </p>
<p>Seek the truth.</p>
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		<title>
		By: Joyce Potts, SRA, AI-RRS		</title>
		<link>https://appraisersblogs.com/bifurcated-appraisal-vs-uspap-scope-of-work-rule-sow/#comment-27822</link>

		<dc:creator><![CDATA[Joyce Potts, SRA, AI-RRS]]></dc:creator>
		<pubDate>Tue, 17 Sep 2019 12:55:38 +0000</pubDate>
		<guid isPermaLink="false">http://appraisersblogs.com/?p=22485#comment-27822</guid>

					<description><![CDATA[You can’t always control the quality of market data based on questionable or faulty Realtor input to the MLS, but I don’t see too many appraisers backing out of assignments for that reason. Ever had an appraisal where you didn’t have a single good comp? Did you back out of that assignment? If you guys are going to fight this battle, fight it on something more than a lame interpretation of the scope of work rule. A bifurcated or hybrid product is really no different than a drive-by appraisal where you are relying on certain extraordinary assumptions about a property. I was doing desktop appraisals for First Union Bank 25 years ago. It never ceases to amaze me how many appraisers will post copies of appraisals that they are reviewing or observing  and point out how incompetent the appraiser is and then wonder why the industry is trying to minimize full appraisals and the higher fees. You can’t have it both ways.]]></description>
			<content:encoded><![CDATA[<p>You can’t always control the quality of market data based on questionable or faulty Realtor input to the MLS, but I don’t see too many appraisers backing out of assignments for that reason. Ever had an appraisal where you didn’t have a single good comp? Did you back out of that assignment? If you guys are going to fight this battle, fight it on something more than a lame interpretation of the scope of work rule. A bifurcated or hybrid product is really no different than a drive-by appraisal where you are relying on certain extraordinary assumptions about a property. I was doing desktop appraisals for First Union Bank 25 years ago. It never ceases to amaze me how many appraisers will post copies of appraisals that they are reviewing or observing  and point out how incompetent the appraiser is and then wonder why the industry is trying to minimize full appraisals and the higher fees. You can’t have it both ways.</p>
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		<title>
		By: Mike		</title>
		<link>https://appraisersblogs.com/bifurcated-appraisal-vs-uspap-scope-of-work-rule-sow/#comment-27497</link>

		<dc:creator><![CDATA[Mike]]></dc:creator>
		<pubDate>Thu, 08 Aug 2019 02:50:39 +0000</pubDate>
		<guid isPermaLink="false">http://appraisersblogs.com/?p=22485#comment-27497</guid>

					<description><![CDATA[In reply to &lt;a href=&quot;https://appraisersblogs.com/bifurcated-appraisal-vs-uspap-scope-of-work-rule-sow/#comment-27490&quot;&gt;Joshua Walitt&lt;/a&gt;.

No one has attacked you in their comments. If you feel attacked, that is on you and you alone. If you are unable to accept the fact that others do not agree with you and state so, perhaps you should not post on public forums. 

It is clear however, there is an ethical question here that you simply do not understand. Simply put, Just because something is allowed, it does not mean you should do it.]]></description>
			<content:encoded><![CDATA[<p>In reply to <a target="_blank" href="https://appraisersblogs.com/bifurcated-appraisal-vs-uspap-scope-of-work-rule-sow/#comment-27490">Joshua Walitt</a>.</p>
<p>No one has attacked you in their comments. If you feel attacked, that is on you and you alone. If you are unable to accept the fact that others do not agree with you and state so, perhaps you should not post on public forums. </p>
<p>It is clear however, there is an ethical question here that you simply do not understand. Simply put, Just because something is allowed, it does not mean you should do it.</p>
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		<title>
		By: Anonymous		</title>
		<link>https://appraisersblogs.com/bifurcated-appraisal-vs-uspap-scope-of-work-rule-sow/#comment-27491</link>

		<dc:creator><![CDATA[Anonymous]]></dc:creator>
		<pubDate>Thu, 08 Aug 2019 00:29:49 +0000</pubDate>
		<guid isPermaLink="false">http://appraisersblogs.com/?p=22485#comment-27491</guid>

					<description><![CDATA[No attacks, but,

Every fee appraiser should have an employee assigned to the state board, who could fill them in on what the board is thinking or considering that might impact them, their friends, and colleagues.

Just so, you know, the appraiser can then hold meetings and let all the other appraisers know what&#039;s in the pipeline.

No wonder it is as bad as it is.]]></description>
			<content:encoded><![CDATA[<p>No attacks, but,</p>
<p>Every fee appraiser should have an employee assigned to the state board, who could fill them in on what the board is thinking or considering that might impact them, their friends, and colleagues.</p>
<p>Just so, you know, the appraiser can then hold meetings and let all the other appraisers know what&#8217;s in the pipeline.</p>
<p>No wonder it is as bad as it is.</p>
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		<title>
		By: Joshua Walitt		</title>
		<link>https://appraisersblogs.com/bifurcated-appraisal-vs-uspap-scope-of-work-rule-sow/#comment-27490</link>

		<dc:creator><![CDATA[Joshua Walitt]]></dc:creator>
		<pubDate>Wed, 07 Aug 2019 23:04:02 +0000</pubDate>
		<guid isPermaLink="false">http://appraisersblogs.com/?p=22485#comment-27490</guid>

					<description><![CDATA[In reply to &lt;a href=&quot;https://appraisersblogs.com/bifurcated-appraisal-vs-uspap-scope-of-work-rule-sow/#comment-27486&quot;&gt;Advocate&lt;/a&gt;.

Advocate, I&#039;m not going to repeat everything I&#039;ve stated on other sub-strings above, but will say the laws and regulations for boards in Colorado allow for members to carry out their normal course of business in industry and professional capacities, in the manner that I do. This is not unique to Colorado. I know of multiple board members from across the country who regularly represent their companies at events, making that role clear.

I am familiar with state requirements, correspond with counsel and state staff when necessary, and otherwise handle situations appropriately within the laws and ethics rules of the state. The count of thumbs-up and thumbs-down, as you suggest, is not a primary concern to me.

As I&#039;ve typed to others in this thread, I respect that some people like anonymity. However, accusations and tearing-down by an anonymous poster is not my idea of any sort of civil discussion. If you care to reveal your identity and have direct discussion, please feel free to email me at jwalitt@hotmail.com. I think the discussion related to content and practice in this thread is excellent (and disagreement is okay!), but the attacks are inappropriate.]]></description>
			<content:encoded><![CDATA[<p>In reply to <a target="_blank" href="https://appraisersblogs.com/bifurcated-appraisal-vs-uspap-scope-of-work-rule-sow/#comment-27486">Advocate</a>.</p>
<p>Advocate, I&#8217;m not going to repeat everything I&#8217;ve stated on other sub-strings above, but will say the laws and regulations for boards in Colorado allow for members to carry out their normal course of business in industry and professional capacities, in the manner that I do. This is not unique to Colorado. I know of multiple board members from across the country who regularly represent their companies at events, making that role clear.</p>
<p>I am familiar with state requirements, correspond with counsel and state staff when necessary, and otherwise handle situations appropriately within the laws and ethics rules of the state. The count of thumbs-up and thumbs-down, as you suggest, is not a primary concern to me.</p>
<p>As I&#8217;ve typed to others in this thread, I respect that some people like anonymity. However, accusations and tearing-down by an anonymous poster is not my idea of any sort of civil discussion. If you care to reveal your identity and have direct discussion, please feel free to email me at <a target="_blank" href="mailto:jwalitt@hotmail.com">jwalitt@hotmail.com</a>. I think the discussion related to content and practice in this thread is excellent (and disagreement is okay!), but the attacks are inappropriate.</p>
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		<title>
		By: Advocate		</title>
		<link>https://appraisersblogs.com/bifurcated-appraisal-vs-uspap-scope-of-work-rule-sow/#comment-27486</link>

		<dc:creator><![CDATA[Advocate]]></dc:creator>
		<pubDate>Wed, 07 Aug 2019 19:49:30 +0000</pubDate>
		<guid isPermaLink="false">http://appraisersblogs.com/?p=22485#comment-27486</guid>

					<description><![CDATA[Mr. Walitt,

 You are twisting words around because you have no sound argument to make. Maybe it is because you are incapable of understanding, or maybe it is your lack of a moral and ethical compass. I don&#039;t know, nor do I care. Your actions are a conflict with your intended purpose serving on the Colorado Appraisal Board.  Anyone who has taken an introductory business ethics course will tell you so.  Anyone who has served on any regulatory Board will tell you so. The Appraisal Institute Ethics Committee will tell you so as will every other professional appraisal organization. It really does not matter if there is or is not a written rule, you have failed the citizens of Colorado. 

Please take a step back and pay attention to the details. This is a public forum for the betterment of the profession and for consumer education.  Your argument with every poster is noted. The likes and dislikes on the comments are noted. Have you been paying attention? No one is in agreement with you. Even if you don&#039;t understand other perspectives, most people know when to stop and retreat. You appear to be lacking this ability.  

Please stop embarrassing yourself, your employer, the Colorado Appraisal Board and most importantly the citizens of Colorado!]]></description>
			<content:encoded><![CDATA[<p>Mr. Walitt,</p>
<p> You are twisting words around because you have no sound argument to make. Maybe it is because you are incapable of understanding, or maybe it is your lack of a moral and ethical compass. I don&#8217;t know, nor do I care. Your actions are a conflict with your intended purpose serving on the Colorado Appraisal Board.  Anyone who has taken an introductory business ethics course will tell you so.  Anyone who has served on any regulatory Board will tell you so. The Appraisal Institute Ethics Committee will tell you so as will every other professional appraisal organization. It really does not matter if there is or is not a written rule, you have failed the citizens of Colorado. </p>
<p>Please take a step back and pay attention to the details. This is a public forum for the betterment of the profession and for consumer education.  Your argument with every poster is noted. The likes and dislikes on the comments are noted. Have you been paying attention? No one is in agreement with you. Even if you don&#8217;t understand other perspectives, most people know when to stop and retreat. You appear to be lacking this ability.  </p>
<p>Please stop embarrassing yourself, your employer, the Colorado Appraisal Board and most importantly the citizens of Colorado!</p>
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		By: Joshua Walitt		</title>
		<link>https://appraisersblogs.com/bifurcated-appraisal-vs-uspap-scope-of-work-rule-sow/#comment-27482</link>

		<dc:creator><![CDATA[Joshua Walitt]]></dc:creator>
		<pubDate>Wed, 07 Aug 2019 18:33:55 +0000</pubDate>
		<guid isPermaLink="false">http://appraisersblogs.com/?p=22485#comment-27482</guid>

					<description><![CDATA[For the record, I should clear the air on my own behalf because I think there is some confusion and misinformation, based on a few comments above and emails I&#039;ve received.

-I did NOT write the blog post that appears on this page. (Yes, the blog references me above; no, I didn’t write it or contribute to it.)
-As part of my job, I recently spoke at a conference on standards and various inspection types commonly conducted. It was clear (per my invitation, calls with the organizer, agenda at the event, slides presented at the event, and my spoken words at the event) that I was at the event representing my company. This is proper and accepted, inviting no confusion about my role.
-I posted a short summary article of my recent presentation to my professional online profile.
-My article was reposted and referenced on other sites (including this site).

Thanks.]]></description>
			<content:encoded><![CDATA[<p>For the record, I should clear the air on my own behalf because I think there is some confusion and misinformation, based on a few comments above and emails I&#8217;ve received.</p>
<p>-I did NOT write the blog post that appears on this page. (Yes, the blog references me above; no, I didn’t write it or contribute to it.)<br />
-As part of my job, I recently spoke at a conference on standards and various inspection types commonly conducted. It was clear (per my invitation, calls with the organizer, agenda at the event, slides presented at the event, and my spoken words at the event) that I was at the event representing my company. This is proper and accepted, inviting no confusion about my role.<br />
-I posted a short summary article of my recent presentation to my professional online profile.<br />
-My article was reposted and referenced on other sites (including this site).</p>
<p>Thanks.</p>
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		<title>
		By: Baggins		</title>
		<link>https://appraisersblogs.com/bifurcated-appraisal-vs-uspap-scope-of-work-rule-sow/#comment-27481</link>

		<dc:creator><![CDATA[Baggins]]></dc:creator>
		<pubDate>Wed, 07 Aug 2019 18:30:39 +0000</pubDate>
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					<description><![CDATA[In reply to &lt;a href=&quot;https://appraisersblogs.com/bifurcated-appraisal-vs-uspap-scope-of-work-rule-sow/#comment-27472&quot;&gt;Certresid&lt;/a&gt;.

It&#039;s all hype and wordsmithing. 

The contention around automation and such, just talking points meant to distract from what&#039;s really happening. 

What&#039;s behind the curtain are corporate investors. 

Amc&#039;s have a boss themselves these days. It&#039;s their corporate responsibility to put share holders interests first. Amc appraisers might be unaware they are forced to discount, to appease capital investors and pay company interest payments.]]></description>
			<content:encoded><![CDATA[<p>In reply to <a target="_blank" href="https://appraisersblogs.com/bifurcated-appraisal-vs-uspap-scope-of-work-rule-sow/#comment-27472">Certresid</a>.</p>
<p>It&#8217;s all hype and wordsmithing. </p>
<p>The contention around automation and such, just talking points meant to distract from what&#8217;s really happening. </p>
<p>What&#8217;s behind the curtain are corporate investors. </p>
<p>Amc&#8217;s have a boss themselves these days. It&#8217;s their corporate responsibility to put share holders interests first. Amc appraisers might be unaware they are forced to discount, to appease capital investors and pay company interest payments.</p>
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		<title>
		By: Joshua Walitt		</title>
		<link>https://appraisersblogs.com/bifurcated-appraisal-vs-uspap-scope-of-work-rule-sow/#comment-27480</link>

		<dc:creator><![CDATA[Joshua Walitt]]></dc:creator>
		<pubDate>Wed, 07 Aug 2019 18:26:12 +0000</pubDate>
		<guid isPermaLink="false">http://appraisersblogs.com/?p=22485#comment-27480</guid>

					<description><![CDATA[In reply to &lt;a href=&quot;https://appraisersblogs.com/bifurcated-appraisal-vs-uspap-scope-of-work-rule-sow/#comment-27468&quot;&gt;Anonymous&lt;/a&gt;.

No one on a public board can oversee a case involving their own employer, friend, co-worker, etc. He or she would recuse oneself (leave the room for the duration and have no involvement in the case).]]></description>
			<content:encoded><![CDATA[<p>In reply to <a target="_blank" href="https://appraisersblogs.com/bifurcated-appraisal-vs-uspap-scope-of-work-rule-sow/#comment-27468">Anonymous</a>.</p>
<p>No one on a public board can oversee a case involving their own employer, friend, co-worker, etc. He or she would recuse oneself (leave the room for the duration and have no involvement in the case).</p>
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		By: Joshua Walitt		</title>
		<link>https://appraisersblogs.com/bifurcated-appraisal-vs-uspap-scope-of-work-rule-sow/#comment-27479</link>

		<dc:creator><![CDATA[Joshua Walitt]]></dc:creator>
		<pubDate>Wed, 07 Aug 2019 18:21:29 +0000</pubDate>
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					<description><![CDATA[In reply to &lt;a href=&quot;https://appraisersblogs.com/bifurcated-appraisal-vs-uspap-scope-of-work-rule-sow/#comment-27463&quot;&gt;Milton P&lt;/a&gt;.

Milton P:

A board’s authority is granted to the board in whole, not to any member individually; so, a suggestion (as you make above) that a person who is a board member should be speaking on behalf of the board when outside of regular board meetings directly contradicts state law/regulation. Rather, if speaking individually outside of a board meeting, the person must NOT represent himself or herself as representing the board.

State rules do – specifically – acknowledge and allow for taking part in industry and professional gatherings, with the expectation that the person not appear to speak for the board (accomplished through slides, spoken words, printed agendas, and or other means). Note that laws applicable to board members vary by state.

Suggesting that a governor might be initiating removal of a certain board member is inappropriate, unprofessional, and off-base in this circumstance.

Stop with the unfounded accusations. I always make it clear I am not representing the board when I take part in an industry or professional gathering. To require that board members stop industry and professional involvement during their time serving would be impractical (since many or most, by default, are involved through the very nature of their work); thus, the state has rules that acknowledge and allow it.

While I respect anonymity, it does nothing to encourage professional accurate discourse. Why not just email me directly at jwalitt@hotmail.com if you have concerns?]]></description>
			<content:encoded><![CDATA[<p>In reply to <a target="_blank" href="https://appraisersblogs.com/bifurcated-appraisal-vs-uspap-scope-of-work-rule-sow/#comment-27463">Milton P</a>.</p>
<p>Milton P:</p>
<p>A board’s authority is granted to the board in whole, not to any member individually; so, a suggestion (as you make above) that a person who is a board member should be speaking on behalf of the board when outside of regular board meetings directly contradicts state law/regulation. Rather, if speaking individually outside of a board meeting, the person must NOT represent himself or herself as representing the board.</p>
<p>State rules do – specifically – acknowledge and allow for taking part in industry and professional gatherings, with the expectation that the person not appear to speak for the board (accomplished through slides, spoken words, printed agendas, and or other means). Note that laws applicable to board members vary by state.</p>
<p>Suggesting that a governor might be initiating removal of a certain board member is inappropriate, unprofessional, and off-base in this circumstance.</p>
<p>Stop with the unfounded accusations. I always make it clear I am not representing the board when I take part in an industry or professional gathering. To require that board members stop industry and professional involvement during their time serving would be impractical (since many or most, by default, are involved through the very nature of their work); thus, the state has rules that acknowledge and allow it.</p>
<p>While I respect anonymity, it does nothing to encourage professional accurate discourse. Why not just email me directly at <a target="_blank" href="mailto:jwalitt@hotmail.com">jwalitt@hotmail.com</a> if you have concerns?</p>
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		By: Certresid		</title>
		<link>https://appraisersblogs.com/bifurcated-appraisal-vs-uspap-scope-of-work-rule-sow/#comment-27472</link>

		<dc:creator><![CDATA[Certresid]]></dc:creator>
		<pubDate>Wed, 07 Aug 2019 15:47:19 +0000</pubDate>
		<guid isPermaLink="false">http://appraisersblogs.com/?p=22485#comment-27472</guid>

					<description><![CDATA[I totally get where anonymous is coming from and why exposing Fannies selling guidelines is so important. What is astounding is that Fannies actions and cavalier attitude regarding hybrids and 1004p “test” pilots.  

These new products are akin too and no different than the FDA approving and then unleashing an drug company’s experimental product on the general public prior to controlled studies. They are akin to using the general public as their guinea pigs. Without disclosing warnings of known or unknown side effects. By marketing the appeal of fast, and cheap there’s to date no little to no evidence of accuracy or questionable bifurcated processes using unqualified inspectors.]]></description>
			<content:encoded><![CDATA[<p>I totally get where anonymous is coming from and why exposing Fannies selling guidelines is so important. What is astounding is that Fannies actions and cavalier attitude regarding hybrids and 1004p “test” pilots.  </p>
<p>These new products are akin too and no different than the FDA approving and then unleashing an drug company’s experimental product on the general public prior to controlled studies. They are akin to using the general public as their guinea pigs. Without disclosing warnings of known or unknown side effects. By marketing the appeal of fast, and cheap there’s to date no little to no evidence of accuracy or questionable bifurcated processes using unqualified inspectors.</p>
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		By: Jack Of All Trades		</title>
		<link>https://appraisersblogs.com/bifurcated-appraisal-vs-uspap-scope-of-work-rule-sow/#comment-27470</link>

		<dc:creator><![CDATA[Jack Of All Trades]]></dc:creator>
		<pubDate>Wed, 07 Aug 2019 13:11:17 +0000</pubDate>
		<guid isPermaLink="false">http://appraisersblogs.com/?p=22485#comment-27470</guid>

					<description><![CDATA[In reply to &lt;a href=&quot;https://appraisersblogs.com/bifurcated-appraisal-vs-uspap-scope-of-work-rule-sow/#comment-27467&quot;&gt;Mike Ford, AGA, GAA, RAA, SCGREA, Realtor®&lt;/a&gt;.

As always go USA ?? mike]]></description>
			<content:encoded><![CDATA[<p>In reply to <a target="_blank" href="https://appraisersblogs.com/bifurcated-appraisal-vs-uspap-scope-of-work-rule-sow/#comment-27467">Mike Ford, AGA, GAA, RAA, SCGREA, Realtor®</a>.</p>
<p>As always go USA ?? mike</p>
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		By: Anonymous		</title>
		<link>https://appraisersblogs.com/bifurcated-appraisal-vs-uspap-scope-of-work-rule-sow/#comment-27468</link>

		<dc:creator><![CDATA[Anonymous]]></dc:creator>
		<pubDate>Wed, 07 Aug 2019 05:10:48 +0000</pubDate>
		<guid isPermaLink="false">http://appraisersblogs.com/?p=22485#comment-27468</guid>

					<description><![CDATA[And he can&#039;t come up with one intended use of a required appraisal, that allows for the scope of the work available in a hybrid appraisal, where an AMC is involved. Not one.

Sure could do it for a homeowner, for the homeowner&#039;s own use, but not for a lender. And homeowners don&#039;t use AMCs.

And someone please explain how an employee of a company, can then sit on a state board and then SUPERVISE, their employer.

Doesn&#039;t that seem like both a conflict of interest, and a conflict of employment relationships?

AMC Final Rule
https://www.federalregister.gov/documents/2015/06/09/2015-12719/minimum-requirements-for-appraisal-management-companies
section 1473 of the Dodd-Frank Act?[1] added a new section 1124 to Title XI of the Financial Institutions Reform, Recovery, and Enforcement Act of 1989 [2] (FIRREA) that established minimum requirements to be applied by States in the registration and supervision of AMCs. An AMC is an entity that serves as an intermediary for, and provides certain services to, creditors.

These minimum requirements apply to States that have elected to establish, pursuant to section 1117 of FIRREA, [4] an appraiser certifying and licensing agency with authority to register and supervise AMCs (participating States).

Section 1473 of the Dodd-Frank Act?[5] also requires the ASC to maintain an AMC National Registry, which will include AMCs that are either registered with, and subject to supervision by, a State appraiser certifying and licensing agency or are subsidiaries owned and controlled by a Federally regulated insured depository institution and regulated by a Federal financial institutions regulatory agency.

https://www.lexology.com/library/detail.aspx?g=724a91e1-94f1-4514-9e30-3749303c7c26
In the employment context, aspects of the duty of loyalty include the duty that the employee ...includes the duty not to misappropriate confidential information or trade secrets ....It also includes the duty to disclose the existence of conflicts or adverse information to the employer. 

And this is true even if the employer is not harmed by the undisclosed adverse interest or information. 

This list is, of course, not exhaustive. There are certainly other situations that can arise in the employment context that obligates an employee to act in the best interests of the employer....]]></description>
			<content:encoded><![CDATA[<p>And he can&#8217;t come up with one intended use of a required appraisal, that allows for the scope of the work available in a hybrid appraisal, where an AMC is involved. Not one.</p>
<p>Sure could do it for a homeowner, for the homeowner&#8217;s own use, but not for a lender. And homeowners don&#8217;t use AMCs.</p>
<p>And someone please explain how an employee of a company, can then sit on a state board and then SUPERVISE, their employer.</p>
<p>Doesn&#8217;t that seem like both a conflict of interest, and a conflict of employment relationships?</p>
<p>AMC Final Rule<br />
<a target="_blank" href="https://www.federalregister.gov/documents/2015/06/09/2015-12719/minimum-requirements-for-appraisal-management-companies" rel="nofollow ugc">https://www.federalregister.gov/documents/2015/06/09/2015-12719/minimum-requirements-for-appraisal-management-companies</a><br />
section 1473 of the Dodd-Frank Act?[1] added a new section 1124 to Title XI of the Financial Institutions Reform, Recovery, and Enforcement Act of 1989 [2] (FIRREA) that established minimum requirements to be applied by States in the registration and supervision of AMCs. An AMC is an entity that serves as an intermediary for, and provides certain services to, creditors.</p>
<p>These minimum requirements apply to States that have elected to establish, pursuant to section 1117 of FIRREA, [4] an appraiser certifying and licensing agency with authority to register and supervise AMCs (participating States).</p>
<p>Section 1473 of the Dodd-Frank Act?[5] also requires the ASC to maintain an AMC National Registry, which will include AMCs that are either registered with, and subject to supervision by, a State appraiser certifying and licensing agency or are subsidiaries owned and controlled by a Federally regulated insured depository institution and regulated by a Federal financial institutions regulatory agency.</p>
<p><a target="_blank" href="https://www.lexology.com/library/detail.aspx?g=724a91e1-94f1-4514-9e30-3749303c7c26" rel="nofollow ugc">https://www.lexology.com/library/detail.aspx?g=724a91e1-94f1-4514-9e30-3749303c7c26</a><br />
In the employment context, aspects of the duty of loyalty include the duty that the employee &#8230;includes the duty not to misappropriate confidential information or trade secrets &#8230;.It also includes the duty to disclose the existence of conflicts or adverse information to the employer. </p>
<p>And this is true even if the employer is not harmed by the undisclosed adverse interest or information. </p>
<p>This list is, of course, not exhaustive. There are certainly other situations that can arise in the employment context that obligates an employee to act in the best interests of the employer&#8230;.</p>
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		<title>
		By: Mike Ford, AGA, GAA, RAA, SCGREA, Realtor®		</title>
		<link>https://appraisersblogs.com/bifurcated-appraisal-vs-uspap-scope-of-work-rule-sow/#comment-27467</link>

		<dc:creator><![CDATA[Mike Ford, AGA, GAA, RAA, SCGREA, Realtor®]]></dc:creator>
		<pubDate>Wed, 07 Aug 2019 04:37:44 +0000</pubDate>
		<guid isPermaLink="false">http://appraisersblogs.com/?p=22485#comment-27467</guid>

					<description><![CDATA[In reply to &lt;a href=&quot;https://appraisersblogs.com/bifurcated-appraisal-vs-uspap-scope-of-work-rule-sow/#comment-27457&quot;&gt;Jack Of All Trades&lt;/a&gt;.

OK, I confess. I had to check. http://www.ft.lk/special-report/IBM-s-Summit-becomes-world-s-fastest-supercomputer-beating-China-s-Sunway-TaihuLight/22-658371

USA takes the lead again! Go USA! Go USA!]]></description>
			<content:encoded><![CDATA[<p>In reply to <a target="_blank" href="https://appraisersblogs.com/bifurcated-appraisal-vs-uspap-scope-of-work-rule-sow/#comment-27457">Jack Of All Trades</a>.</p>
<p>OK, I confess. I had to check. <a target="_blank" href="http://www.ft.lk/special-report/IBM-s-Summit-becomes-world-s-fastest-supercomputer-beating-China-s-Sunway-TaihuLight/22-658371" rel="nofollow ugc">http://www.ft.lk/special-report/IBM-s-Summit-becomes-world-s-fastest-supercomputer-beating-China-s-Sunway-TaihuLight/22-658371</a></p>
<p>USA takes the lead again! Go USA! Go USA!</p>
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		By: Mike Ford, AGA, GAA, RAA, SCGREA, Realtor®		</title>
		<link>https://appraisersblogs.com/bifurcated-appraisal-vs-uspap-scope-of-work-rule-sow/#comment-27466</link>

		<dc:creator><![CDATA[Mike Ford, AGA, GAA, RAA, SCGREA, Realtor®]]></dc:creator>
		<pubDate>Wed, 07 Aug 2019 04:33:34 +0000</pubDate>
		<guid isPermaLink="false">http://appraisersblogs.com/?p=22485#comment-27466</guid>

					<description><![CDATA[In reply to &lt;a href=&quot;https://appraisersblogs.com/bifurcated-appraisal-vs-uspap-scope-of-work-rule-sow/#comment-27465&quot;&gt;Anonymous&lt;/a&gt;.

You&#039;ve never seen me support hybrids. I&#039;m pretty vehement in my opposition to them. I&#039;m also pretty vocal in my opposition to Boards that do not follow USPAP themselves in disciplining licensed appraisers.

I&#039;ll go a step further. Collectively State Boards will NEVER enforce USPAP uniformly. More and more are adopting their own concepts of what constitutes compliance without the benefit of their own legislatures decision-making rights. They simply change the rules to something more convenient

The problem isn&#039;t Mr. Walitt or anyone else espousing personal views. It&#039;s having a federal law, interpreted by a private corporation; and then having 50-57 different regulatory agencies adopting slightly varied implementing laws, and THEN having AARO (another private corporation) circumvent the intent of their own legislature AND the feds by doing end runs out of the public eye to get TAF to make foolish changes to ease their tasks.

TAF needs to make public what they are teaching state &quot;Investigators&quot; down in Florida. 

Compliance with USPAP needs to be taken over by the Feds. &#038; USPAP should not be rewritten or modified on whims. Limit changes to once every five years max. Barring national emergencies.]]></description>
			<content:encoded><![CDATA[<p>In reply to <a target="_blank" href="https://appraisersblogs.com/bifurcated-appraisal-vs-uspap-scope-of-work-rule-sow/#comment-27465">Anonymous</a>.</p>
<p>You&#8217;ve never seen me support hybrids. I&#8217;m pretty vehement in my opposition to them. I&#8217;m also pretty vocal in my opposition to Boards that do not follow USPAP themselves in disciplining licensed appraisers.</p>
<p>I&#8217;ll go a step further. Collectively State Boards will NEVER enforce USPAP uniformly. More and more are adopting their own concepts of what constitutes compliance without the benefit of their own legislatures decision-making rights. They simply change the rules to something more convenient</p>
<p>The problem isn&#8217;t Mr. Walitt or anyone else espousing personal views. It&#8217;s having a federal law, interpreted by a private corporation; and then having 50-57 different regulatory agencies adopting slightly varied implementing laws, and THEN having AARO (another private corporation) circumvent the intent of their own legislature AND the feds by doing end runs out of the public eye to get TAF to make foolish changes to ease their tasks.</p>
<p>TAF needs to make public what they are teaching state &#8220;Investigators&#8221; down in Florida. </p>
<p>Compliance with USPAP needs to be taken over by the Feds. &amp; USPAP should not be rewritten or modified on whims. Limit changes to once every five years max. Barring national emergencies.</p>
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		By: Anonymous		</title>
		<link>https://appraisersblogs.com/bifurcated-appraisal-vs-uspap-scope-of-work-rule-sow/#comment-27465</link>

		<dc:creator><![CDATA[Anonymous]]></dc:creator>
		<pubDate>Wed, 07 Aug 2019 04:19:51 +0000</pubDate>
		<guid isPermaLink="false">http://appraisersblogs.com/?p=22485#comment-27465</guid>

					<description><![CDATA[In reply to &lt;a href=&quot;https://appraisersblogs.com/bifurcated-appraisal-vs-uspap-scope-of-work-rule-sow/#comment-27461&quot;&gt;Mike Ford, AGA, GAA, RAA, SCGREA, Realtor®&lt;/a&gt;.

Angst? Board members know this is happening, by the companies they grant license to, to operate in their states, oh but appraisers are responsible for the scope of the work. No angst here, just wondering when the RICO and collusion parts kick in from the licensing authorities, against those who are more than appraisers.

After all, as you know, there is more than one definition of market value, and even other types of values, with definition, yet, no one can come up with the appraisal requirements that allow for these hybrid reports. It aint the selling guide. Nope, and not Va or FHA. So where is the appraiser&#039;s guide for the scope of the work, for an intended use, which is none of these? Isn&#039;t any? Oh, why are these types of reports then being advocated across the profession, while the state&#039;s who are supposed to have oversight of these companies, just standing around and watching?

Almost makes you wonder what AMCs can get away with saying or advocating for.

But no angst. Just lots of uncomfortable questions.

Want another one? Where is the Appraiser&#039;s Waiver of Regulation for a pilot program, using people&#039;s real estate values as guinea pigs? Appraisers are provided with relief and can institute hold harmless agreements, when, if, &quot;the pilot&quot; doesn&#039;t work and the property owners feel like they might have been harmed?

Just lots and lots of uncomfortable questions.]]></description>
			<content:encoded><![CDATA[<p>In reply to <a target="_blank" href="https://appraisersblogs.com/bifurcated-appraisal-vs-uspap-scope-of-work-rule-sow/#comment-27461">Mike Ford, AGA, GAA, RAA, SCGREA, Realtor®</a>.</p>
<p>Angst? Board members know this is happening, by the companies they grant license to, to operate in their states, oh but appraisers are responsible for the scope of the work. No angst here, just wondering when the RICO and collusion parts kick in from the licensing authorities, against those who are more than appraisers.</p>
<p>After all, as you know, there is more than one definition of market value, and even other types of values, with definition, yet, no one can come up with the appraisal requirements that allow for these hybrid reports. It aint the selling guide. Nope, and not Va or FHA. So where is the appraiser&#8217;s guide for the scope of the work, for an intended use, which is none of these? Isn&#8217;t any? Oh, why are these types of reports then being advocated across the profession, while the state&#8217;s who are supposed to have oversight of these companies, just standing around and watching?</p>
<p>Almost makes you wonder what AMCs can get away with saying or advocating for.</p>
<p>But no angst. Just lots of uncomfortable questions.</p>
<p>Want another one? Where is the Appraiser&#8217;s Waiver of Regulation for a pilot program, using people&#8217;s real estate values as guinea pigs? Appraisers are provided with relief and can institute hold harmless agreements, when, if, &#8220;the pilot&#8221; doesn&#8217;t work and the property owners feel like they might have been harmed?</p>
<p>Just lots and lots of uncomfortable questions.</p>
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		By: Mike Ford, AGA, GAA, RAA, SCGREA, Realtor®		</title>
		<link>https://appraisersblogs.com/bifurcated-appraisal-vs-uspap-scope-of-work-rule-sow/#comment-27464</link>

		<dc:creator><![CDATA[Mike Ford, AGA, GAA, RAA, SCGREA, Realtor®]]></dc:creator>
		<pubDate>Wed, 07 Aug 2019 04:18:02 +0000</pubDate>
		<guid isPermaLink="false">http://appraisersblogs.com/?p=22485#comment-27464</guid>

					<description><![CDATA[In reply to &lt;a href=&quot;https://appraisersblogs.com/bifurcated-appraisal-vs-uspap-scope-of-work-rule-sow/#comment-27463&quot;&gt;Milton P&lt;/a&gt;.

Got it.]]></description>
			<content:encoded><![CDATA[<p>In reply to <a target="_blank" href="https://appraisersblogs.com/bifurcated-appraisal-vs-uspap-scope-of-work-rule-sow/#comment-27463">Milton P</a>.</p>
<p>Got it.</p>
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		<title>
		By: Milton P		</title>
		<link>https://appraisersblogs.com/bifurcated-appraisal-vs-uspap-scope-of-work-rule-sow/#comment-27463</link>

		<dc:creator><![CDATA[Milton P]]></dc:creator>
		<pubDate>Wed, 07 Aug 2019 01:21:43 +0000</pubDate>
		<guid isPermaLink="false">http://appraisersblogs.com/?p=22485#comment-27463</guid>

					<description><![CDATA[In reply to &lt;a href=&quot;https://appraisersblogs.com/bifurcated-appraisal-vs-uspap-scope-of-work-rule-sow/#comment-27462&quot;&gt;Mike Ford, AGA, GAA, RAA, SCGREA, Realtor®&lt;/a&gt;.

He is not representing the Board. He is representing his employer and speaking on topics that will come before the Board for decisions. He has opened up the Board and state to huge liability on every disciplinary case in which the Board has opined on the topic in which he was part of the discussion and decision. If he was speaking as a representative of the Board on a topic the board has opined, there would be no issue. That is not what he has done.]]></description>
			<content:encoded><![CDATA[<p>In reply to <a target="_blank" href="https://appraisersblogs.com/bifurcated-appraisal-vs-uspap-scope-of-work-rule-sow/#comment-27462">Mike Ford, AGA, GAA, RAA, SCGREA, Realtor®</a>.</p>
<p>He is not representing the Board. He is representing his employer and speaking on topics that will come before the Board for decisions. He has opened up the Board and state to huge liability on every disciplinary case in which the Board has opined on the topic in which he was part of the discussion and decision. If he was speaking as a representative of the Board on a topic the board has opined, there would be no issue. That is not what he has done.</p>
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		<title>
		By: Mike Ford, AGA, GAA, RAA, SCGREA, Realtor®		</title>
		<link>https://appraisersblogs.com/bifurcated-appraisal-vs-uspap-scope-of-work-rule-sow/#comment-27462</link>

		<dc:creator><![CDATA[Mike Ford, AGA, GAA, RAA, SCGREA, Realtor®]]></dc:creator>
		<pubDate>Wed, 07 Aug 2019 01:07:23 +0000</pubDate>
		<guid isPermaLink="false">http://appraisersblogs.com/?p=22485#comment-27462</guid>

					<description><![CDATA[In reply to &lt;a href=&quot;https://appraisersblogs.com/bifurcated-appraisal-vs-uspap-scope-of-work-rule-sow/#comment-27460&quot;&gt;Milton P&lt;/a&gt;.

Isn&#039;t that a bit generalized? When I worked in government (IRS) we had appraisers and CPAs frequently conducting webinars to tax service providers. Mr. Oldmixon of Texas (Board Member) used to regularly give public statements. FEMA would come to give a presentation to just about anyone that wanted one. There are guidelines, of course. Unless we know what they are in his state I don&#039;t see how any can be critical.

At Appraiserfest, I had the pleasure of sharing the public speaking dais for the Leadership  Panel with Mr. Jim Park, Executive Director of the ASC (along with many other highly respected &#039;leaders&#039;). There was no conflict. I just don&#039;t see how Mr. Walitt&#039;s appearance was a conflict.]]></description>
			<content:encoded><![CDATA[<p>In reply to <a target="_blank" href="https://appraisersblogs.com/bifurcated-appraisal-vs-uspap-scope-of-work-rule-sow/#comment-27460">Milton P</a>.</p>
<p>Isn&#8217;t that a bit generalized? When I worked in government (IRS) we had appraisers and CPAs frequently conducting webinars to tax service providers. Mr. Oldmixon of Texas (Board Member) used to regularly give public statements. FEMA would come to give a presentation to just about anyone that wanted one. There are guidelines, of course. Unless we know what they are in his state I don&#8217;t see how any can be critical.</p>
<p>At Appraiserfest, I had the pleasure of sharing the public speaking dais for the Leadership  Panel with Mr. Jim Park, Executive Director of the ASC (along with many other highly respected &#8216;leaders&#8217;). There was no conflict. I just don&#8217;t see how Mr. Walitt&#8217;s appearance was a conflict.</p>
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