Mat J, simply…..its because the fee and turn time is the only criteria that is important to them.

That was a fun read, thanks.
HOAs may not, after July23, 2023, create governing documents and declarations that effectively prohibit the construction, development, oruse of additional housing units as required in HB 1110 (middle housing) and HB 1337 (accessory dwelling units).

What upstanding law makers. They say HOA rules shall not be effected, so if an hoa says no more than one unit, that rule stands. Then they turn around and say they can never issue new governing documents with that language, effectively prohibiting all new development from taking a safe haven from higher density housing, and also freezing all existing hoa rules in time for literally ever. The few that are able to hold out will be arguing decades from now about antiquated provisions or some lacking hoa rule, and it will be impossible for them to issue updated by laws, otherwise they’ll lose the no higher density clause. Insane people in government, they have no respect for the people in their communities or their way of lives.

An ‘impact fee’ for ‘longer automobile trips’. Gee, try to get away from the crowds, you get taxed for that too. The new progressivism is redefining taxes as fees, so they stack them on there without even needing to ask, nor require a vote. One presumes the fees are substantial, for an appraiser to be asking about them in relation to home value. Liberalism, find a cure.

#4 &#5 are as expected. They’ve jumped the ship now, off the farm, flew the coop. How come nobody consulted with the banksters before implementing this? It’s all relevant, one could theoretically still check h and b use for a single unit in an hoa complex, or even a single unit outside of an hoa complex. Simply because those units comparatively will absolutely skyrocket in pricing compared to already developed multiple unit properties. There is going to be a lot of new security fencing and innovative parking solutions. High density housing is the nightmare that never ever ends. Try not to trip over the ebikes on your walk to work.

Baggins & SP,
Have you seen the DOL/DOC release today regarding HB1110 ????
https://deptofcommerce.app.box.com/s/t23totbz5th5e723ls6f7y3p8hub63t7

FAQs 4&5 are the relevant ones and contrary to what you might think, I am more than a little surprised by them.

In counties that I service, the counties have gone on record to state they will not know if the parcel and surrounding infrastructure could or would support such a build until and only AFTER the application for a permit has been completed. If there is a permit being applied for, I could agree there would be an issued. If there is no permit applied for, nor issued, the appraiser would be making a lot of assumption that they can’t complete said work. We have to complete the assignments based on the known facts as of the effective date of the assignment and not a date in the future. Therefore, the HUB would be to build the house because it known that is infrastructure and support it, there is a permit to build the SFR, there is no intent to subdivide, etc as of the effective date of the assignment. So, I stand comfortable with where I’m at.

Then we’re back to Jeremy Bagott’s articles if the specific state in question, has properly adopted the updated standards for that 2 year cycle, which I think nearly most have not. TAF has been pushing unregulated ethics book updates and alterations for decades, acting like a government to itself. Where as other industries simply issue a code for their industry, the code (rules guidelines) goes through appropriate state administrative and notice process, subject to public scrutiny and response writing, may be needed to be voted in, and only then; is a legitimate enforceable standard.

Under those arguments, TAF simply updating the uspap book does not cover an appraiser. Because the pertinent question for the state authority which may pursue any appraiser, or those pursuing appraisers with their lawsuits is simple; Which uspap book has this state entered into their own systems as the enforceable code? Don’t count on the latest 2 year cycle being the code which the appraiser is held to account in a court of law. Maybe for the board, despite their failure to enforce administrative procedures acts. Not for independent attornies whom are aware of this problem.

There are important legal concepts regarding due process here. Also highlighting how TAF’s supposed power is a paper tiger. How they continue to price gouge a captive audience, operate above and outside the law every else has to abide, behave like a government to themselves, and are clearly outside of their scope of authority on many matters. Bagott writes a lot about these concepts, encourage everyone to back read.

https://mailchi.mp/9a9fc75a5e34/texas-judge-to-rule-on-rolling-delegation-of-uspap-9091366

administrative procedure code, rolling incorporation by reference, etc, etc.

Most would probably not entertain some magical exception to newly incorporated state rules like you mentioned that bill was all about. Appraisers whom take that route may be subjected to myriads of legal challenges by those whom are trying to roll the rules back. Other guidelines for appraisers may be included in city, county, state, or federal law, which would supersede uspap. There is no jurisdictional exception for these non profits and private entities to be able to force appraisers to defy existing law or tradition. That’s why I don’t use ANSI, because it’s not code in my state, and why I do not vainly believe that the only rule or ‘law’ I must be aware of is the uspap book. Wherever I operate, I have read city, county, state, various municipal codes relevant to the task, etc.

If TAF does carve out some magical exception to the existing traditions and rules, this could be seen as justification for more states to follow suit in this apparently incompetently conceived experiment, where central planners supersede the will of many voters and violate the rights of many others whom do not agree with these concepts of changing land use and development allowances. So be careful what you wish for regarding any talk of TAF somehow providing meaningful arbitration on the matter.

In regards to your statement about TAF. I agree they have no say over what local or even states do regarding land use and zoning. However, if the TAF concludes that performing an appraisal on a property that allows for more than 4 dwelling units exceeds the qualifications of a Cert Res appraiser, then state appraisal review entities will use that benchmark to determine if an appraiser has exceeded their abilities to appraise under their licensure, and if it is determined that the appraiser did exceed their licensure then E&O insurance will not cover it.

Can you send that to CFPBevidence@gmail.com PLEASE Thankyou

Where should I send to you?

Can you please forward that to me Toni can post on linked in and quote it accurately. I was having some fun at their expense on that platform.

https://www.denvergov.org/files/assets/public/v/1/community-planning-and-development/documents/zoning/denver-zoning-code/interpretations-determinations-clarifications/cidu.pdf

CIDU Complete Independent Dwelling Unit. I guess we do have co housing allowances after all. They are limited to only certain zoning areas though.

One has to invest substantial time to navigate the zoning code complexities.

Interesting. Government bureaucrats. Sort of like Denver, but worse. Denver kept a somewhat clear distinction between commercial and residential, increased density allowances, most builders scraped, rebuilt higher density with smaller split up parcels, or took a commons condo approach. One building per one parcel, even if attached, limited ADU allowance only where allowable via specific zoning code. Those are the rules.

Trying to force local municipalities to allow higher density, or even require additional buildings be low income accessible. Local residents will lose control, developers will sweep in among the confusion, acquire opportunistically, encroach on the hold outs who will eventually fold, and just like that; disproportionately high rental volume and declining home ownership.

Encroachment takes many forms and comprehensive city planning such as careful zone controls is really important. If they need more housing units, they simply have to allow the denser city area zoning footprint to expand, preferably only in aging out areas in need of redevelopment. The free market and developers take care of the rest.

TAF is not the local authority, they have no jurisdiction or enforcement powers, anywhere, outside of paper licensing for individuals. Your local regulatory guidance for real estate, appraiser, and broker practices is instantly out moded and needs completely reformed. This is why some states require an analysis on impacts on state budgets and estimates of man hours spent, in order to more comprehensively consider legislative proposals.

Check this out. Denver zoning code. When one researches individual lots you also get these local plat maps with color coded zoning, where block by block, there can be different code. I don’t see a ‘co housing’ zone in there, lol.
https://www.denvergov.org/Government/Agencies-Departments-Offices/Agencies-Departments-Offices-Directory/Community-Planning-and-Development/Denver-Zoning-Code

Class really has very little class, if any.

They keep removing my comments on their posts. Guess they don’t like answering questions.

That’s funny you mention that. Are you in the Ventura County area? I received that same exact bid proposal. I quoted $450 and a 2 day turnaround to see if that was low enough for the sake of this conversation and lost the bid LOL
I received a different bid request from them at 3:00 AM as well. Haven’t gotten one (bid proposals) in months so I wonder how many of them are reading these replies and freaking out a little. Normally they ask me to bid on the $10M+ properties in Malibu. So nice of them!!!
2 More posts on their LinkedIn today as well.

We are reaching out today because we have an order that is a rush or possibly more complex or rural assignment. We only bid assignments that have a special circumstance such as a rush inspection and delivery or a specific competency requirement due to complexity. We ask for both turn time and fee quotes so the end user understands your required compensation. We review bids as received and truly appreciate your partnership with Class Valuation in delivering the best service to our customers. Please also note that by submitting a bid you are certifying that you are geographically competent within the subject’s market area, and maintain the proper access to MLS to be able to appropriately research the data needed on this file.

To view this order, please click here to submit your quote as opposed to sending it in an e-mail reply.

Have a great day!

Class

Take what you would want to get paid for your time to do a cookie cutter tract home next door to your office.
For every hour or portion you spend in your car charge your hourly rate.
Both directions.
How much hour/portion do you spend on comp pics for that job? add it.
Then add fees for PITA orders like MH or 1025 or review or condo or 3,000′ 1 bedroom geodesic log home on 100 acres oceanfront with a private beach…

ie;
base fee is $525 for next door.
you drive 30 minutes each way and your hourly rate is $100/hr =$625
and then its a MH =$775
and then its on acres =$875-975…
then its ERC =$1075-1275
then its a review.. wow-jeez so now i gotta do my own work =$1275+plus re-do the other guys work =$1275 but discount it a little bit since its only 1 inspection so maybe ~$2200? maybe…

math
Its not just for kids.

Jaydee…. you can’t just say that without additional context or consideration…. Are you saying a tract home appraisal with 3 model match sold sales within 3 blocks and both an active and pending sale nearby to round out the lender’s request for those as well should cost $800 and that I should charge the same $800 for a home with similar utility to that property, but with comps that are over a mile away in every direction, none of which are model match sales? you should not be talking total fee, but hourly rates so that there is a uniform/relevant comparison. Arbitrary “base fees” are not a good basis for comparison.

I understand what you are saying about the Govt should not be able to restrict discussion about fees, but fees are completely dependent on market. I live 20 25 miles from downtown Seattle, but because I am across a body of water in a semi-rural area, the amount of “time” it takes me to just take my comp pics is way longer than your typical tract appraiser in the Seattle MSA. Add the lack of homogeneity and it takes me at least half as long on the simplest of appraisals to complete an assignment as it would for someone just a short distance from me. So, I have no issue with talking fees, but they should be based on hourly rates, not gross billing for each report. I target $100/hr in my quotes for lender work, $150/hr for litigation (not including court testimony or deposition time) because that is what other professionals charge for their services.