The American Guild of Appraisers Statement to House Financial Services Committee Hearing Madam Chairman and Members of the Committee, on behalf of the American Guild of Appraisers/OPEIU Guild 44 (AGA) thank you for the opportunity to submit this statement in connection with today’s hearing on the real estate appraisal profession and the regulation of appraisers and appraisal practice. The AGA is a membership organization that seeks to represent the interests of appraisers related to federal and state regulation of appraisal practice and to industry practices that impact on appraisers and appraisals. In addition, working closely with other like-minded organizations including...
NAR believes that lenders should be prohibited from retaining the services of an AMC where the lender maintains any level of ownership. Frank Gregoire‘s written testimony to the United States House of Representatives Committee on Financial Services Subcommittee on Insurance, Housing and Community Opportunity before the Appraisal Oversight Hearing … APPRAISAL ISSUES AND CHALLENGES There are a myriad of circumstances and issues working to hinder the recovery of the nation’s housing market. Among them, and often overlooked, are those related to the credible valuation of real property. A credible valuation provided by a licensed or certified professional 1) ensures the...
My testimony today will focus on issues that are particularly relevant to state regulatory officials. Challenges Facing State Appraisal Boards Enforcement States established appraiser licensing and certification programs as a result of the Financial Institution Reform, Recovery and Enforcement Act (FIRREA) of 1989. These agencies issue appraiser licenses and certifications to those individuals who possess the education and experience requirements promulgated by the Appraiser Qualifications Board of The Appraisal Foundation. The agencies also oversee compliance by appraisers with the Uniform Standards of Professional Appraisal Practice (USPAP), state law and agency rules. These programs have been set up in a variety...
The goal of the Uniform Standards of Professional Appraisal Practice (USPAP) is to promote and maintain a high level of public trust in appraisal practice by establishing requirements for appraisers. With this goal in mind, the Appraisal Standards Board (ASB) regularly solicits and receives comments and suggestions for improving USPAP. Proposed changes are intended to improve USPAP understanding and enforcement, and thereby achieve the goal of promoting and maintaining public trust in appraisal practice. The ASB is currently considering changes for the 2014-15 edition of USPAP. All interested parties are encouraged to comment in writing to the ASB before the...
A large lender has recently amended their appraisal policy regarding comparables. The table below was taken from their general information Correspondent Bulletin. The change greatly expands what and how an appraiser filters data. It appears as though this lender wants to stand over the shoulder of the appraiser to make certain that the filtering is to their liking. It brings backseat driving to a new level. Imagine driving someone to a destination and having to provide a detailed list of every possible route to this destination as you arrive. Imagine having to provide detailed routes that you never seriously considered...
Analyzing of market trends The nation’s largest professional association of real estate appraisers published guidance June 4 to help appraisers analyze market trends. The Appraisal Institute’s “Guide Note 12: Analyzing Market Trends” addresses to what extent appraisers are responsible for recognizing changes in market conditions, and what steps appraisers must take to ensure due diligence is done regarding the analysis of market trends. The Guide Note states, “Analyzing current and anticipated market conditions is more complicated – and more critical – when a market is rapidly changing, either upward or downward.” Adequate market analysis must be completed before highest and...
Have you taken your 2012-2013 National USPAP Update yet? Section 1455.160: (Paraphrased) A real estate appraiser must complete the 7-hour National USPAP Update Course or its equivalent within 6 months after the effective date of USPAP. Those real estate appraisers issued a license more than 6 months after the effective date of USPAP shall complete the 7-hour National USPAP Update Course within 6 months after licensure. This has been Illinois law since January 20, 2011 which means that it was meant to begin with the 2012-2013 release of USPAP. I get a lot of appraisers who say the following: “But,...
The FDIC continues to sue residential appraisers in connection with origination appraisals and review appraisals performed for failed lenders between 2003-2009 on loans now in default. It may be helpful, or scary, for appraisers and AMCs to see for themselves exactly what kinds of alleged USPAP violations or other errors the FDIC is claiming in lawsuits against appraisers. Therefore, I have copied below the FDIC’s actual allegations against several appraisers. These are word-for-word the entirety of the FDIC’s claimed errors against these appraiser defendants. Please don’t shoot the messenger. I’m a lawyer, not a USPAP expert, but even I know...
I’ve written about this before but it’s well worth repeating. Please keep in mind, this is and has been the position of the Illinois board. If you appraise a property for Client A, and two years later, Client B wants you defend your report, you’re not required to answer their queries about the report created for Client A. What if Client B threatens to blacklist you for not cooperating in the review? When does the client relationship end with Client A? USPAP states: An appraiser must protect the confidential nature of the appraiser-client relationship. That seems clear enough. So, who...
Petition Opposing Coercive and Abusive Behavior of Chase Bank and Other Lenders Against Appraisers Please consider signing the online petition launched by John Dingeman opposing the coercive and abusive behavior of Chase Bank and other lenders against appraisers. Stop Intimidating, Threatening, and Bullying Appraisers Chase Mortgage Banking, like other financial institutions have come into possession of appraisals where a loan has been assigned or sold to them. If Chase had any issues with these appraisals during the underwriting process when the loans were written, they would have asked the appraiser’s “Client” for clarification, explanations, and/or corrections. With every foreclosure, Chase...
