Federal Agency in Charge of Appraisers

Federal Agency in Charge of Appraisers Will Be a Nightmare. Having a federal agency in charge of appraisers will be a NIGHTMARE. Leave it to the states as it is now. ALL appraisers should be SWAMPING their state representatives with calls & emails in OPPOSITION to newly introduced H.R. Bill entitled: Fair Appraisal and Inequity Reform Act of 2022. DO IT NOW. **Remind them all that the job of a Professional Real Estate Appraiser is to PROTECT THE PUBLIC TRUST. That’s what we are in place for!

With all of the ridiculous changes proposed with “PAREA”, we know exactly where this is headed. Appraisers coming out of their “PAREA” certification will be able to start appraisal work with no supervision at all. PLUS, AMCs will be recruiting them like crazy in order to be “in house” appraisers that will do exactly as they are told.

APPRAISER INDEPENDENCE WILL BE NO MORE

Whether or not appraisers are “organized” under a common banner, we are still able to exert our influence on our OWN REPRESENTATIVES to fight this garbage before it’s too late.

CONTACT YOUR REPRESENTATIVES TODAY! MULTIPLE TIMES!

But please, please, please don’t say anything so stupid that it will be turned around and used against us.

That’s already happened with an appraiser from my state that emailed an ignorant rant to Maxine Waters about this.

Here’s my letter to my own representative about this Bill:

The Honorable Gregory F. Murphy, MD
U.S. Congressman, North Carolina, 3rd District
1105 Corporate Dr., Suite C
Greenville, NC 27858
Phone: 252-931-1003

Dear Dr. Murphy,

I am writing to express my deep concern for proposed legislation I have become aware of.

This legislation is being proposed by Congresswoman Maxine Waters (D-California), Chairwoman of the House Committee on Financial Services. This proposed legislation comes as a result of the hearing held March 29, 2022, entitled;

Devalued, Denied and Disrespected; How Home Appraisal Bias and Discrimination are Hurting Homeowners and Communities of Color

You may read the discussion draft of the proposed legislation at the link above. This proposal would create a new federal agency and replace the current Appraisal Foundation and it’s Boards.

I watched the entire hearing with great interest as I am a Professional Appraiser. While the issue of bias in appraisals appears to be a new issue, the subject actually began back in 2019. A hearing was held June 20, 2019 entitled;

What’s Your Home Worth? A Review of the Appraisal Industry

That hearing introduced data presented by Andre Perry of the Brookings Institute, which began the basis for actions since taken to attempt to address a conclusion brought on by the data. However, the actual data and the data collection procedure have never been analyzed to determine if the conclusion drawn was accurate and correct.

Since that time, there have been studies by Fannie Mae that have relied on the same data presented by Andre Perry from the Brookings Institute. See “Fannie Mae; Appraising the Appraisal

Since the Brookings Data has never been properly researched to confirm its accuracy, using it as a basis for other studies causes issues. The importance of this issue deserves extensive independent study before any action is taken.

In the course of my education and training as an Appraiser, I was constantly reminded that to do my job correctly and effectively, I always had to come from a position of neutrality. Remain neutral, unbiased (not for or against anyone) not as an advocate for any party to the transaction. I was taught that an appraiser is the ONLY party to a transaction that does not benefit directly and that a Professional Appraiser is in place to *protect the public trust.*

I genuinely and sincerely believe that and that is the way I have always done my job. The vast majority of appraisers do the same. No one is saying that there is never a case of racial bias in any appraisal, however if there are such cases, each state has an independent Appraisal Board to file complaints. These boards perform extensive investigations into all complaints against appraisers and take appropriate disciplinary action, including revoking their licenses when needed.

I do NOT agree that creating a new federal agency is the solution…While I agree wholeheartedly as a Professional Appraiser that ANY type of bias in appraisals is completely unacceptable, I do NOT agree that creating a new federal agency is the solution. I believe that it will create unintended consequences for the borrowing public and for the Appraisal Profession, as well as cause severe changes in our economy of which mortgage lending and home buying is an important part. Previous attempts at legislation affecting the Appraisal Industry have not necessarily been complete successes. I refer you to the Home Valuation Code of Conduct / HVCC (2009) and to the Dodd–Frank Wall Street Reform and Consumer Protection Act (2010).

I encourage you as my representative to get involved immediately. Time is of the essence as Congresswoman Waters gave the Financial Services Committee Members only 5 days from March 29, 2022 to respond to her proposal. This legislation is being put on an unnecessarily “fast track”.

Thank you for taking action on an issue that affects so many.

Sincerely,
(my contact info redacted)

Now… let’s get to work putting a stop to this ridiculous Bill.

By LadyT. The author is a Certified Residential Appraiser.

opinion piece disclaimer
Image credit flickr - Dan Gaken

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11 Responses

  1. Avatar Coach says:

    Done. Thank you for speaking up and taking action LadyT!

    5
  2. Avatar Bruce W Lennick says:

    We will be managed just like the Post Office and Amtrak, Sure glad I am getting out of the appraisal business,

    9
    • Avatar Bryan says:

      That is the goal. Make it “frightening” everyone will quit. Then scream “We can’t find an Appraiser”! Better use alternatives.

      0
  3. Baggins Baggins says:

    What mechanism and/or department manages the legislative review to assure that legislation is not in conflict with other legislation? That’s whom we should write to as well. FAIR is basically seeking to codify a host of issues as law, which are otherwise direct violations of Dodd Frank Reg Z on Appraiser Independence.

    4
  4. Avatar hammering hank says:

    I wonder what these (5) individuals think?

    Witness List:

    David S. Bunton, President, The Appraisal Foundation
    Stephen S. Wagner, Senior Appraiser, Terzo & Bologna, Inc., on behalf of the Appraisal Institute
    Jeff Dickstein, Chief Compliance Office, Pro Teck Valuation Services, on behalf of the Real Estate Valuation Advocacy Association
    Andre Perry, David M. Rubenstein Fellow, Metropolitan Policy Program, the Brookings Institute
    Joan N. Trice, Founder, Collateral Risk Network

    3
  5. Avatar Pat Turner says:

    Fools’ gold!!

    1
  6. Baggins Baggins says:

    Just got a HUD 20 years of national home ownership month deal in the email. There it is again, this word;  ‘equitable housing’. I still can’t figure out what that means. And I’m not sure HUD even knows either, but they appear to enjoy throwing that slogan statement around. What is equitable housing?  A digital process?  A slogan?  A catch phrase?  Something tangible?  A measurement of housing density and if so, compared to what?  How could a person walk up to any given real property and then describe ‘it’s equitable features’, specifically? Has the governments interpretation of equitable housing changed from then to now?
    http://www.huduser.gov/portal/pdredge/pdr-edge-featd-article-051722.html
    05/22 HUD article using the slogan equitable housing.
    https://www.huduser.gov/portal/pdredge/pdr-edge-trending-081318.html
    08/18, previous use of equitable housing in hud articles.
    https://dsnews.com/daily-dose/07-21-2021/hud-secretary-testifies-on-equitable-housing
    HUD 07/21, political persons statements on the matter.
    If the problem is housing density and over priced housing which limits affordability, why are appraisers being blamed for existing housing character, price, and existing location? Are we supposed to pretend there is more space and less density or something or the homes are actually located somewhere else?  I just don’t get it.

    0
    • Avatar Bryan says:

      That is the REAL QUESTION!! What is expected from us? What is needed? Is there a goal we don’t know about? Can someone on that panel please list (exactly) what the expectations are for future Appraisers? I mean an actual list of 5 things. I’ll bet we already provide them.

      1
      • Baggins Baggins says:

        The heart of the matter and root cause of the problem is not the appraisal or the appraisal methodology. The root cause of the problem is the pervasive misconception in society that governments responsibility is to provide entitlement.

        Otherwise they’d all get a clue and stop begging with their hands out for more corporate and citizen welfare programs, and just up and move to different locations where they feel a more personal sense of; equitability.

        Try as they might, they’ll never successfully take a feeling and turn it into a real property characteristic. It’s just not fair that I live in this high density city with no parks! It’s just not fair all those credit cards I took out now cause me to get a higher lending rate. It’s just not fair about how my continued subscriptions to welfare services continues to erode the dollar and fuel additional inflation which causes housing to be unaffordable. It’s just not fair the way the government spends all this money and gives none to me. They sold it you bought it. More government is certainly not the solution, but that’s where they turn. And now they’re trying to bring the fear of covid back for an additional power grab. Who in their right mind still trusts this government?

        2
        • Avatar Bryan says:

          Yes! And it is important to understand that this is the governments goal. Make everyone need something from them so they can justify their existence. BTW – it is working. It all should come to a grinding halt in about 2 more generations.

          0
  7. The goal is to disrupt appraiser independence and nothing more. After 2008 and all the appraiser independence laws and AMC’s were supposed to be “protecting” the appraiser (but they are not and now AMCs are competing for lender business by making deals work instead of protecting independence… so will THEY be held responsible when the market takes a bigger dive than it did in 2008 in the next 6-12 months?) It left the lenders with the choice of kicking good appraisers off their panels, which they did, but still, it wasn’t enough. PAVE is a direct assault on appraiser independence and we haven’t heard a thing about independence since of course. We won’t hear about PAVE or any other idiotic equity laws once the housing market begins to really tank. How can anyone blame the appraiser for crashing the market and at the same time blame the appraiser for “stealing value and equity” from random people who apparently live in neighborhoods that no one ever pays cash in. Btw, I went to the AARO meeting on this and was literally bullied, shamed, and victimized for trying to discuss this. There is nothing like a conference where people get together to discuss nonbias and equity and mistreat and abuse the people at the conference for not being JUST LIKE THEM. :0) I believe that is called discrimination, and bias. It was disgusting, just like the idea that everyone at this conference knew better but they were such cowards that they acted like children who were afraid to stand up and say the right thing because they might be shamed, like they believed I was… NOT! I was embarrassed for everyone from the Appraisal Foundation, and everywhere else who sang the party line and let the conference continue when there was no data and still is no data showing anyone has been “De-valued or injured in any way” by an appraiser, anywhere. (I’ll save the rest of you right now from embarrassment until I am ready to name you! Yes, I know you don’t like me. I don’t like you either. You don’t like me because I am right and you think you are powerful and special but dishonest people are neither one.) And recall, I repeatedly said that discrimination and bias is always unacceptable. However, appraisers do not create value, they study and report facts from data, and telling appraisers that they are not allowed to report the data and facts accurately IS discrimination and bias and it is ethically compromising what we do, not to mention that it is predatory.

    0

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Federal Agency in Charge of Appraisers

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