Comments on: Federal Valuation Agency Impact on Appraisers & the Public

By: Mary T Thompson

Mary T Thompson — Sat, 23 Jul 2022 11:59:24 +0000

What is the BILL number for this Discussion Draft. I am searching in the Congress.gov website and I am not finding the Bill. Thanks!

By: Kristina

Kristina — Sat, 23 Jul 2022 02:44:40 +0000

The thing is that there simply is NOT an appraisal bias issue. This is going to create an agency funded by taxpayers that is headed to solve a problem that is non-existent. Appraisers do not create value, we report what buyers are willing to pay, which varies greatly in differing social-economic areas. It just isn’t about race. I understand that there has historically been great discrimination based on race, but not today. This is not a systemic appraisal issue.
This agency is only going to create problems for appraisers, deter potential new appraisers from entering the profession and waste taxpayers dollars. We already have agencies that govern us to a great extent, we do not need this agency and the waste and headaches it will create. If they want consumers to know that they can file a complaint, then just do the media blitz and inform them of the rights they already have. Then if they want appraisers to have more diversity training, then develop the courses and mandate them. Those 2 actions will essentially do what this act intends. The database is just a terrible idea and violation of privacy. I do not think that is a good idea at all. This is a great example of government having a good intention but having no idea how to implement an effective solution. The inequity in real estate is not an appraisal issue, it is a socio economic issue which traces back to access to education, mental health care, access to child care, basic health care and low wage jobs.

By: CJK

CJK — Fri, 22 Jul 2022 18:37:39 +0000

If I say that I am a black LGBTIQ will that help prevent me from getting reviewed?

3 more years and I am done with this disaster. Who would want to be an appraiser anymore? Just do away with the profession and give people whatever they want seems to be the mantra. The taxpayers will cover it all.

By: Mary T Thompson

Mary T Thompson — Fri, 22 Jul 2022 18:17:24 +0000

Holy Crap is all I can say. We all better write our Reps or we are screwed. I will NOT let the Government force me to tell them my race and ethnicity that anyone can search for and see online. Talk about racism. So that means that lenders can just choose minority Appraisers for Minority neighborhoods because we all know that if like races appraise like neighborhoods, the values will be perfect. As someone noted here, it is always about LOW appraisals. They never complain about the High Appraisals. Let’s just over value by 20% and that should make everyone happy. BUT you can’t do that in White neighborhoods. Oh no! That is not allowed. I digress….

Listen up people, they are proposing that all appraisals will be available ONLINE to the public. So I guess this new committe which is replacing ASC & AQB will be taking out the confidentiality section of USPAP. I for one do not want a home appraisal on my house available for the public to see. I AM SURE CONGRESS DOES NOT WANT THEIR HOME APPRAISALS TO BE SEEN BY THE PUBLIC. SURE THEIR NAME MAY NOT BE ON THE REPORT, BUT IF PEOPLE CAN FIND THEIR ADDRESS THEY CAN SEARCH IT THAT WAY. This is insanity! Start now making your business decisions toward NON lender work, BUT they even have civil suit information for Personal Appraisals in this proposal. Plus they are allowing 2 million dollars in Media blitz compaigns telling people about how they can SUE you for Appraiser Bias OR for any reason they feel the value is incorrect. This is going to snowball into something really bad. People will be suing/filing complaints left and right and since we will be on the hook for thousands upon thousands if their “CORRECTED” value (who decides on that number?) is higher than the Appraiser’s biased or just plain misguided value. So it is not all about bias it is if anyone thinks your value is off, they can sue you and if the powers that be say yep, that value was too low you pay the difference. E & O will skyrocket in fees.

ALSO IF A COMPLAINT IS FILED THEY WILL FULLY REVIEW AND INVESTIGATE ALL THE APPRAISALS YOU DID WITHIN THE PRIOR 24 MONTHS PERIOD. ARE YOU KIDDING. THAT WOULD TAKE FOREVER TO SUBMIT AND FOR THEM TO REVIEW FOR INHERENT BIAS.

There are so many unintended or should I say INTENDED consequesces here that my head is swimming. If this passes next year my lender buisiness which is only 20% will END and thank God I am within a few years of retirement.

By: Mary T Thompson

Mary T Thompson — Fri, 22 Jul 2022 17:59:08 +0000

In reply to ShenValley Appraiser.

Exactly! This is outrageous. I can just see the E & O coverage moving forward will skyrocket because the Appraiser could be on the hook for several thousand or more dollars. This is a huge mess. Everyone better write their Representatives. I sure plan to!

By: That Scott Guy

That Scott Guy — Fri, 22 Jul 2022 16:52:52 +0000

Oooof! Well, there it is. A FEDERAL valuation agency…

How much gov’t oversite and regulation is needed?! This move is an attempt at pure control of the people, nothing more. The Gov’t is working on control of food, healthcare, and now housing. Remember, who get’s to decide?

We will all own nothing and like it.

By: jaydee

jaydee — Fri, 22 Jul 2022 16:47:54 +0000

Rules for Appraisals:
#1 There is no such thing as a “Low Appraisal”.
#2 In case you don’t believe that there are low appraisals; See rule #1

By: Seneca

Seneca — Fri, 22 Jul 2022 16:40:24 +0000

This isn’t good. They are really searching hard for someone’s head to serve up. Also, Sounds like the FVA will be a lot alike the CFPB, which is mentioned in this bill. The CFPB does not have any congressional oversight, no appeal process and acts on its own on what punishment is dealt out. I’m sure the E&O insurance companies are taking note of this. Man, November can’t come soon enough.

By: ShenValley Appraiser

ShenValley Appraiser — Fri, 22 Jul 2022 16:17:56 +0000

The verbiage buried in the Penalty section says it all as to who is actually pushing the buttons of the Junior Staff members who wrote this proposed Bill –
the penalty amount of damages will be the amount between the “corrected valuation” (NOT Appraisal) and the erroneous one (i.e., the lower value). Who determines the “corrected valuation” ?- this is not spelled out – and the choice of the word “valuation” over Appraisal is a red flag.

By: Charles Finely

Charles Finely — Fri, 22 Jul 2022 15:36:10 +0000

The creation of an national appraiser database with our “self reported gender and race” is an fairly obvious showing of what this bill is purely intended to do. At some point why would an appraiser take an appraisal order for anyone of a different race or gender where the risk of litigation, claims of discrimination, and a federal hounding will make the order not worth taking.

Almost no one has ever complained about an appraisal being too high, only about it being too low. This bill (and all others like it in California and other states) only consider the “too low appraisal” a reality and seem to assume that too high of an appraisal has no negative consequences. Why would appraisers, at some point, fight this? Soon everyone will just make sure to hit whatever number they need to to avoid lawsuits. It seems crystal clear that that will be the choice in the near future to either give inflated appraisals using bad math and bad standards, or face lawsuits.

It is a worthy goal to work for more diversity in the appraisal industry and to increase the number of appraisers throughout the nation, but this bill will not do that and will worsen the problem. Soon the honest appraisers will leave, no young appraisers will enter except those that can get licensed through the new Federal program without needing a trainer, and housing valuations will be in the hands of a few government agencies and large tech companies.

In Australian it was proposed that the Federal Government subsidize housing to help the lower and middle class by buying 40% of the house, while the owner would only need to purchase the other 60%. Who will care what the value of the home is when the government owns 40% of it? The government can’t default. If it’s been proposed in Australia I would put odds at 100% it’s being considered somewhere in the halls of government here in the US.

It’s tough to watch real simple common sense answers get thrown out the window to make room for political bills with no basis in reality.

By: David Lostra

David Lostra — Fri, 22 Jul 2022 14:24:29 +0000

Do we need oversight for appraisers such as this bill is suggesting? unfortunately I believe that we are attempting to place more oversight to try and control a dynamic industries such as real estate. Yes there needs to be standards, but when the government imposes control to lessen the boom and bust cycles that are natural in economics. We eventually cause more harm then good. This bill will eventually lead into a direct action that would allow policy makes to direct real estate prices if desired.