Improper Direction to Appraisers
…specific prohibited direction to appraisers involved in federally regulated transactions…
Improper direction to appraisers as a new special lender condition
Honorable Ladies and Gentlemen:
The following article appeared in a recent online post at https://appraisersblogs.com/appraisers-asked-2-overlook-weed-cultivation (also copied to this letter following our inquiry).
We consider the original author to be a credible source.
Due to the serious implications of any appraisal management service giving such specific prohibited direction to appraisers involved in federally regulated transactions we believe it to be our duty to bring this to your collective attention.
We respectfully request that each Federal Regulatory Agency review this issue and contact Bank of America and confirm whether this direction to appraisers is at their behest, and constitute their instructions and special assignment conditions / directives?
At the same time, we also ask the TAF/ASB to publish an expedited and updated Advisory Opinion specific to this issue. We believe existing USPAP and Advisories already deal with this but due to the gravitas the referenced corporations are perceived to have nationally on lending and appraisal issues, we believe an unambiguous response by the ASB is urgently needed.
As TAF can only speak to USPAP, we further ask that each applicable federal regulatory agency having jurisdiction over all possible transactions that may fall into this category state or restate the Federal Government’s position with respect to property appraisals where conditions that violate federal drug laws (or any other federal law violations) are observed.
Is it only marijuana related violations of federal law that appraisers are being asked to keep mum about, or could this practice of hear, see & speak no evil also include other drugs such as heroin processing, opium growth, methamphetamines /speed, or cocaine/crack ‘cooking’?
Is the appraisal management service’s directed carve-out only an exception to the federal drug laws; or will other federal laws such as prohibitions against child porn, sexual slavery & human trafficking for prostitution, or kidnapping / holding of illegal immigrants hostage for payments also be directed to be ignored?
Will FNMA and FreddieMac be disclosing to potential investors that the bundled securities offered to Wall Street and international as well as national investors may include properties known to be in violation of United States drug laws that may result in the seizure of the collateral for those securities?
Similarly, is the Veterans Affairs Department going to knowingly be guaranteeing mortgage loans where cultivation of marijuana for personal and or commercial use? Is HUD aware it may in the future be insuring loans secured by property subject to potential forfeiture to other federal agencies?
Will B of A be required to disclose to their investors that they are engaged or intend to engage in risky lending practices where the collateral can be seized under existing federal laws?
Will unions, insurers, and municipal – state retirement systems that invest in real estate also be told the portfolio(s) could include property subject to seizure?
It’s doubtful incidents of this type will be as rare as after-the-fact public denials may suggest. If that were the case, then the obvious question becomes “Why was it necessary for B of A or CoreLogic implement such a policy-directive in the first place?”
Lastly, isn’t it time all federal agencies and GSE’s reconsider their over reliance on CoreLogic (CL) and their various services, if they (CL) think actions like this are acceptable? Certainly, they should immediately sever any and all business relationships and/or information sharing programs with companies that think it is acceptable to ignore federal law.
We recognize federal agencies cannot control CoreLogic’s membership or undue influence on the boards of MISMO and The Appraisal Foundation but partnerships with GSEs could be controlled could they not?
Additionally, the ongoing use of the CoreLogic data monopoly by the Treasury Department and all other federal agencies using RealQuest or Realist or other analytics from this corporate conglomerate should be reviewed before the reliance is so great that no matter what violations of federal laws are espoused or facilitated, a blind eye becomes the only solution.
We think the federal government may already have become too dependent on this monopoly.
Following is the CoreLogic communication as it was posted at the above link.
Engagement Letter Update – Marijuana Cultivation and Residential Appraisals
On March 15, 2018, CoreLogic Valuation Solutions will update the lender specific instructions for all Bank of America products. As a result, a new engagement letter will be generated for any open CoreLogic Valuation Solutions appraisal assignments in AppraisalPort.
New Marijuana Cultivation Appraisal Guidelines to be added in Bank of America Engagement Letter:
If marijuana cultivation is observed during the appraisal property inspection, it shall not preclude the assignment from being completed and delivered to Bank of America. In these instances, do not inquire specifically as to the purpose/legality of any cultivation activities. Do not request any specific information (such as grow permit/license) from the owner/occupant/entry contact regarding any cultivation activities.
The appraiser should photograph all areas required by the assignment type and report/analyze physical changes/conditions/characteristics that impact value/marketability of the property, as applicable.
If you have any questions, please contact the scheduler listed on your engagement letter.
Corelogic Valuation Solutions
Submitted on behalf of or appraisal members, and the 12 ½ million members, retirees and taxpaying consumers of our parent unions #44OPEIU, AFL-CIO.
Michael F. Ford
American Guild of Appraisers
Chairman NAPRC /V.P. Special Projects
Mobile (714) 366-9404
AGA Office (301) 377-0099
AGA Letter regarding Improper direction to appraisers as a new special lender condition
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CoreLogic, Bank of America, and Wells Fargo. You got to love it.
ServiceLink sent a similar notice:
“APPRAISER BULLETIN – March 15, 2018
BANK OF AMERICA – MARIJUANA CULTIVATION AND RESIDENTIAL APPRAISALS
The purpose of this Appraiser Bulletin is to inform appraisers of the requirements for appraisal reports completed for Bank of America when marijuana cultivation is present at the subject property.
• Marijuana cultivation observed during an appraisal property inspection shall not preclude the assignment from being completed, should the appraiser feel comfortable with completing the inspection.
• If marijuana cultivation is observed during the appraisal property inspection, the following expectations apply:
• should photograph all areas required by the assignment type
• should limit conversations with the owner/occupant/entry contact to items which pertain only to the subject property and that are necessary for assignment completion
• is required to report/analyze physical changes/conditions/characteristics that impact value/marketability of the property, if applicable
• is required to report/analyze any observed health and safety concerns
• is NOT required to inquire specifically as to the purpose/legality of any cultivation activities
• is NOT required to request any specific information (such as grow permit/license) from the owner/occupant/entry contact regarding any cultivation activities
As always, thank you for your work with ServiceLink!”
Highest and best use as if vacant; and as improved are required elements. For (all) residential property, if quantity of growth observed appears to be for commercial purposes (tough call!), then you have to address it. That requires questions. Form reports specifically ask if existing use is legal(X), legal non conforming (grandfathered use) or illegal. We typically think of these as strictly land use. Try defending to your state board if a complaint is filed by feds, that you never even asked if the (significant grow) use is legal.
Further, we appraise property to assist lenders in determining its suitability as collateral for loans. Most (all?) title insurance companies wont insure title on such properties. Does that affect the suitability as collateral for FNMA and their investors?
It’s NOT about pot. Its about AMCs TELLING appraisers they don’t have to do things that most appraisers KNOW they MUST do.
Tommy, the addresses are shown above if you want to send a copy of the ServiceLink communication.
There is a moral hazard here. Marijuana on schedule 1 is the primary problem. Paint me red.
A bunch of years ago, before cannabis laws, I accepted a VA assignment in a small community outside if Riverside.
The owner alerted me to his rabid dog, isolated in the garden the other side of the pool fencing. When inspecting, I climbed on a bench to look at the roof and the gardens. I discovered his dog was named MARY JANE was so sick that she was colored Bright green. I got the giggles, but restrained myself, and finished the inspection. I included the owners warning, the name and description of the rabid dog in the VA report.
The owner is not your client, you are responsible to the lender, however their are courtesies and you can extend these courtesies, if you can defend yourself from litigation.
Frequently inspecting apartments, and SFR’s, you see “stuff” maybe un-identifiable, maybe not.
Often you could inform the agent, or owner to harvest before photography, and have more conforming pictures of the back yard.
We are part of the Real Estate industry, maintaining our independence from powerful lobbying groups dictates we must find a way to be honest and up right while preserving our industry.
The Banking industry seems lately our biggest threat.
Last time I checked, we were appraising the REAL ESTATE and not the activities of the people occupying the dwelling. There are a myriad of criminal activities that could cause “seizure” of property. Shall we question homeowners to see if their income taxes are paid up as well while we are at the property? What a shaky argument. Our job is to value the real estate, period – not make a moral decision about the occupants of the dwelling and the activities they engage in. The only exception I see is in “cooking” (meth) situations that we can observe an obvious environmental hazard to the CONDITION of the real estate – otherwise this is none of our darn business. Further, are you saying appraisers should have some type of expertise to identify these items? This is a slippery slope I don’t want to go down. Save your moral outrage about drug laws for the ballot box but it has no place in our UNBIASED professional analysis.
Apparently you’ve missed the entire point of several articles. There is ZERO moral outrage about the pot. None.
There is extreme moral outrage about a bank and their AMC TELLING us not to see or investigate any conditions that might be necessary for us to perform a USPAP compliant real estate appraisal. Directing us NOT to inquire about permits is the same as telling us not to ask homeowners about any other permits they might need for a use of property.
The fact that we know title insurance companies won’t fund loans where this is a factor shows someone is concerned about NOT disclosing. DOJ does have a good point about the money laundering side as well.
Michael I say this with all respect due. As you are an SRA I KNOW that you know when or if you should make inquiries. We’ll ask about possible commercial aspects of a fruit orchard or almond grove but we can’t ask the same if the crop is pot?
A commercial crop is one thing. But HOBBIES inside a RESIDENTIAL property are what we are talking about here. Permits for “land use” are one thing, but do you go back to every backyard garden you encounter and check to see if that’s really a tomato plant? Of course not. Their requirement is balanced and reasonable. It says we aren’t qualified to determine what a hemp plant is or isn’t- and we are not. You are comparing “obvious” visual things that a reasonable person can determine – like a fruit orchard – to some type of hobby plant someone might have in or on their property. This gets too far into personal uses of the property that are none of our business and have absolutely NOTHING to do with the real estate. Insurance companies won’t fund a lot of things – again, that has NOTHING to do with what I am to be considering on a real estate appraisal. I’m not an insurance company nor a judge of the risk of the activities of the borrower to the loan. Are we also to be experts in criminal law? I have a degree in criminal law and I can’t tell you with 100% certainty the exact status of federal drug laws due to disagreements over the 10th amendment – the new state laws have not yet been tested at the supreme court. And all these lender requirements say – is that if you aren’t comfortable, leave. If you do the appraisal, this is an area you, as an appraiser, aren’t qualified to deal with so leave it alone. If you want to start sticking your nose into an area you are not qualified to determine – from either a botany or legal standpoint – go ahead but I hope you have great E&O insurance that covers you the first time you keep someone from getting a loan because you express a concern on an unbiased appraisal about the personal gardening activities of a homeowner. If you see a cross and a bunch of chairs in a basement rec room used for a bible study, do you check their “permits” to see if they might have a commercial church use of the house going on? Again, separate out PHYSICAL things that affect the real estate and ACTIVITIES the occupants are engaged in. An oil well physically affects the property. A hemp plant on the deck, garden or on even planted on the back 40 – does not. I work out of my home partially. If an appraiser came to my house and saw a desk and printer in the 4th bedroom, would it be ok for him to ask me if I have a home business permit for my activities in home and what tasks I performed on my laptop – if they were personal or business. You know, to make sure I had the right “permits” for my use of my house. Of course not. To your original statement – the bank is not telling you not to “see” something. They are telling you that you are not qualified to know WHAT you are “seeing” in that case at all. I agree.
So many great examples of government over reach.
Hi Michael – appreciate the views. I don’t know where you got the idea we are talking about “hobbies”. The entire issue is about an AMC telling appraisers on behalf of a lender to NOT DO THEIR JOBS.
I don’t see CL or B of A saying need not ask about obviously small personal consumption quantities (which itself would be hard to define, but at least would give some guidance of where they are going with the directive). What they did say was not to ask about use, intended use, permits, legality etc..
I’ve appraised pot grow warehouses (hard money with client awareness); foreclosed retail commercial property where the feds had raided and shut down the prior pot business, and a mix of other types where significant amounts OR retail sales (clearly commercial) were factors.
My job is to report what is there and that may reasonably impact real property ownership and marketability. That’s all. I’m not there to moralize. In order to do MY job, I ask questions. THAT is what we are being told NOT to do coupled to a broader ambiguous follow up cover their ass clause. We aren’t talking about a little decorative starter plant, or even a couple 4 foot high plants in five gallon buckets in a garage or bedroom.
We don’t need a law degree to interpret laws. What we do need to do is follow USPAP. Period. If this is such a non issue, why was it necessary for B of A to adopt the new policy?
In this instance it happens to have involved pot. It could have involved any other appraisal issue as well.
For what it’s worth, the communication to the Federal Reserve Board of Governors has been responded to. They are looking into the matter which is all that we (AGA) requested they do.
I find it ironic that after all the concern over the years that certain clients/entities like FHA were expanding our scope to things we aren’t qualified to look at (i.e. operating mechanicals and appliances for FHA) now we have an appraisal “organization” arguing to expand our scope of work to something no (or very few) appraisers are qualified to deal with.
I’m happy you’ve appraised pot warehouses. Guess what – 99.9999% of the orders that we’re talking about here are NOT that. Your extreme, crazy examples do not prove a “rule” for the majority of normal, residential appraisals. Your initial argument is based on the premise that this is a common and far-reaching issue.
If you would like to expand your scope of work and try to be an expert and identify what is a pot plant and what isn’t – be my guest. The vast majority of appraisers would NOT like that responsibility. If the client said “do not ask about ABC mechanical issues that you know nothing about” – guess what – no problem. Exclusion. Extraordinary assumptions. Disclaimers. That’s what they’re for. That’s what SCOPE OF WORK is for – so thank you very much my USPAP responsibility is just fine. Do those things “affect marketability”? Could be. But guess what, NOT MY ROLE TO DETERMINE.
But since you think appraisers should have the ability to “interpret” federal drug laws, unsettled constitutional issues and be amateur botanists to determine what might be an illegal drug on someone’s property – again I say, good for you. Go for it. You don’t like the policies of this particular client? Great. Don’t work for them. Why was the policy necessary? – that’s an easy one. Because there are appraisers out there like you confused about their actual responsibilities and role in the process. It’s the same reason client requirements have many things in them they tell appraisers not to do – because at one point some over-zealous appraiser thought THAT was their job as well. Why does the URAR say in bold print that “Race and the racial composition of the neighborhood are not appraisal factors”? Seems silly in 2018 to have to print this on the form, right? Because at some point some appraisers thought this was something they should consider – they probably said things like “well, it DOES affect the marketability of the property. It’s part of the market. Shouldn’t I be allowed to ask about this? It’s my ‘job'” Good luck to you – but don’t assume your skewed view is something the majority of appraisers – let alone residential appraisers – want to see happen. You’re opening a can of worms I’d love to see stay shut.
The point has expanded to “That not all appraisals are made for FNMA or FHA loans”. Even then the appraiser should include an engagement letter clarifying what is being measured and to what rules he is following.
When the inspection and or the investigation reveal that the property will not qualify, you can’t just walk away from the job or throw a figure on the form. You should have a provision for a cancelation fee, or write the best report you CAN and try to collect your fee. If you work for a company you should have some way to protect your reputation and license, the insurance won’t. Hopefully your employer will.
We are exposed to many kinds of property and entitlements, not all are clearly R.E.. Estimating the value of a trust deed by just measuring the underling value of the RE is incomplete, if our assignment is for value in trade.
Appraising the value of a house and the adjoining acreage, is incomplete without any entitlements the acreage might have, or have been represented as having. Appraising for a future value in a pioneering neighborhood, would be incomplete, without discussing the future of the neighborhood.
None of these possible assignment would fit of a form nor be considered by an ordinary loan committee.
The contracts of B. of A. etc. when made by the lender-bank are not favorable to the appraiser, all of these standard contracts are for standard property’s and standard properties are not ordinary.
To beee professional we must control our product
I appraise houses, not plants. Beyond my scope of work. Lender can hire a botanist if they so choose!
I’m amazed at the number of “appraisers” that are more than willing to completely ignore their obligations under USPAP, and find ways to rationalize not doing their jobs when it involves issues they have personal biases for.
Sidestep away folks! It’s your license.
As for my not working for companies that do things like this directive from CL? I don’t. I also don’t do hybrids or any of the other things known to be destroying our profession.
By the way Michael, do NOT attempt to put words in my mouth or tell me what I think. You don’t have a clue. Race??? You’ve clearly crossed over into loony tunes land now.
Anything to side step the underlying issue, right? Neither a client nor their agent AMC can direct us to complete an appraisal for an FRT in a manner that does not comply with USPAP. Seems pretty simple.
I was speaking about issues, but since you want to get personal with this (“loony tunes” – IT’S ON THE FORM – READ IT) then let’s lay ALL our cards on the table about who and what you really are.
Not every single thing in a property is our responsibility. Please, Mr. USPAP expert, quote me the exact section and lines that apply here. Specifically. Exactly. Tell me how I’m MANDATED BY USPAP to look at this under the Scope of Work rule. Since I “don’t have a clue”.
Those pesky extraordinary assumptions. How dare they write “sidesteps” into USPAP.
The truth is you are VP of an extremely minor appraisal “organization” that is trying to make up an issue to appear to be “doing” something because you want to “fight” for appraisers. Where is the AI, the ASA, or for that matter, the ASFMRA? Is the AGA the only organization that thinks this is important? Surely an ASFMRA member has been asked to appraise a pot farm by now? I realize that you have 3 “send in your fee” designations next to your name as well as pretending “state certification” is a designation, but the adults here will deal with this on our own – we don’t need the mighty AGA to come save us. People like you dealing with government officials is what gives real appraisers a bad name. Try fixing the 10 spelling and grammar errors on your Mission Statement website first and then get back to us.
Michael, Odd after your opening with offensive language (‘crazy extreme examples’) you are objecting to ‘it becoming ‘personal’. You also offered an offensive view that I am commenting on something I have no qualification to be commenting on because I am not a botanist.
You are an SRA; a generally recognized & respected level of achievement, yet you insist on remaining oblivious to the original issue and its real estate appraisal impact (that of an AMC directing appraisers to perform in a manner that is contrary to USPAP requirements).
As for being a VP in a ‘minor’ appraisal association, we have successfully aided over 100 appraisers in the past two years to refute incorrect state complaints; and aided in the opposition to the TriStar waivers. What have you (or AI done) to help their members defend against wrongful complaints?
I have personal MAI friends and a few have had past consent agreements they signed because no one would help them from AI, and the costs of attorneys were too high.
We helped stop AI’s California AB 624 efforts dead in its tracks with a single phone call after it had already been passed by the state legislature. TAF didn’t do it. CaCAP didn’t do it and even ASA despite considerable effort didn’t do it. OPEIU did that. I ‘ll concede that AI was able to get similar legislation passed in other states, and later SB 70 in California that ASA only, took the opposition lead on). ASA ALSO tries to serve their appraisers-always.
The point Michael is that rather than sitting around on our hands and doing nothing, we TRY. Repeatedly. With and without other organizations, including reaching out to AIs Government Affairs Director. Simple fact is our interests are not always compatible. OUR only interest is in helping appraisers. No other hidden agendas. No international expansion dreams and aspirations. No high salaries for directors or other executives. In fact, no low salaries either. We’ve had some successes; and some areas we are still working on. Appraiser independence is one of them.
Mike, I’m unimpressed by claims of a degree in law. Let me know when and if that translates into passing a state’s bar exam and becoming a qualified attorney.
As for USPAP cites – here:
SR1-1 (a) be aware of, understand, an correctly employ those recognized methods and techniques that are necessary to produce a credible appraisal; (b) not commit a substantial error or omission or commission that significantly affects an appraisal; and (c) not render appraisal services in a careless of negligent manner such as making a series of errors that, although individually might not significantly affect the results of an appraisal, in the aggregate affects the credibility of tose results.
SR 1-2(e) identify the characteristics of the property that are relevant to the type and definition of value and intended use of the appraisal, including:
(i) its location and physical, legal and economic attributes;
(ii) real property interest to be valued;
(iii) any personal property, trade fixtures, or intangible items that are not real property but are included in the appraisal;
(iv) any known easements, restrictions, encumbrances, leases, reservations, covenants, contracts, declarations, special assessments, ordinances, or other items of a similar nature; and
(f) identify any extraordinary assumptions necessary in the assignment;
(comment) USPAP 2018-19 page 17 lines 494-499 “An extraordinary assignment may be used only if: …[bullet 2] the appraiser has a reasonable basis for the extraordinary assumption; use of the extraordinary assumption results in a credible analysis; and the appraiser complies with the disclosure requirements set forth in USPAP for extraordinary assumptions.”
SR1-3(a) pg 17 line 510 “land regulations”
SR1-4 (c) When an income approach is necessary for credible assignment results, an appraiser must:
(i) analyze such comparable rental data as are available and/or the potential earnings capacity of the property to estimate the gross income potential of the property; (ii)(iii)&(iv) are only relevant IF the questions that we are prohibited from asking under BofAs and CLs new policy develops information that the property and use is actually a commercial enterprise
(d) When developing an opinion of the value of the leased fee estate or leasehold estate , an appraiser must analyze the effects on value, if any, of the terms and conditions of the lease(s). (Really difficult to do if you are prohibited from asking about them whenever pot appears to be a factor-or if a lease-even a residential lease, specifically precludes such uses).
(g) When personal property, trade fixtures, or intangible items are included in the appraisal, the appraiser must analyze the effect on value of such non-real property items. When sale price includes all the grow lights; irrigation system and potting containers in the 1,200 sf basement (or more)…what are you going to do? Simply fail to disclose the inclusion of personal property in the sale and then just state you didn’t include any personal property in value??
SR 1-5 Analyze agreements of sale, options, listings etc…just ignore them and claim they “weren’t reasonably available?”
Michael Im not going to recite all the corollaries under SR2, or definitions (bias, etc) but you should get the idea. I will remind you of the Preamble page 1 lines 9 & 12 though.
We don’t KNOW in advance what we are going to find at a property. The issue is (again) not the pot or our lack of qualifications as botanists. Its more about honesty and integrity.
The issue is and was from my first post – that an AMC on behalf of a major named client is directing us to not even ask typically relevant questions…and THAT is a prohibited assignment condition. All the rest is illustrative.
Michael a California State Supreme Court Judge once said in a speech to our community group that he could argue either side or an issue with equal alacrity. He also added that both sides cant be right. This is not an issue of can an appraiser weasel their way around federal laws, regulations and USPAP. It is a case that we should not have to, or even want to.
It’s taken too many years to learn how to do things the right way. Appraisers shouldn’t be put in positions of having to thread a needle of sophistry in order to do their jobs professionally.
If its all a tempest in a teapot, then WHY did CoreLogic and Bank of America feel the need to tell us not to ask questions about legality of use or possible commercial intent?
Set aside your pro pot bias (& anti ‘me/AGA’ bias) and focus on the only issue – that of an AMC telling us not to ask questions that may well be required in order to keep our licenses.
Thanks for being so verbose as to prove you really have no idea about anything. “Pro Pot Bias”? Really? Actually, I’m personally, rapidly against it, but YOU apparently are the one that can’t separate personal bias from a professional responsibility because I dare argue one point of view on an appraisal matter you ASSUME (incorrectly) that it is my personal view. Thanks – we all now know where YOUR personal bias must be.
I have a degree in criminal justice, class of 1997 from Wichita State University – with an emphasis in constitutional law. I may have mistyped “criminal law” in my midnight posting rush- don’t you EVER try to call MY professional qualifications considering you are the one adding 14 designations from things like NAR’s “GAA” designation. I’ll attach a copy of my degree hanging on the wall behind me if you want. What degrees do YOU have that apply here, sir?
You keep asking the same, ignorant questions over and over – and I keep answering them “Why did Corelogic feel the need to…” Because of people like you. Period.
Yes, I’ve read Standards 1. Thanks. Have you read the Scope of Work Rule?
Please – Mr. Ford – explain to me how an appraiser is to obtain competency to determine what a hemp plant is and is not? Since one could potentially be in ANY residential dwelling, doesn’t that mean that, by your contentions here, EVERY residential appraiser in America has to be competent to visually identify a hemp plant? Please explain THAT logic to us. I mean, might any residential appraiser potentially run into a house with such a plant, and by your logic above, would be violating USPAP if they didn’t identify it and consider its impact on the dwelling? Why must I identify a hemp plant but I’m not required to determine if there are roots in the sewer line? Or whether a visually obvious crack in the foundation presents a structural problem. With the crack – I can see it. Do I have to consider it based on your logic of what I have to “identify”? Or can I use one of those crazy extraordinary assumptions in that case? That’s fine, right – I’m not qualified to determine structural stability. But gosh darn I’d better be ready to figure out what those plants are and how they affect the subject. There’s no way out of that one without “weaseling” out of my “job”, right?
You stated “Michael, Odd after your opening with offensive language (‘crazy extreme examples’) you are objecting to ‘it becoming ‘personal’. ” I so hope you don’t do review work since you can’t seem to separate PEOPLE from THINGS. “Crazy examples” is an indication of the ideas you presented. Calling YOU crazy would be personal. I’m sorry you can’t recognize the difference.
You go on and keep on keeping on with your skewed ideas. Good luck to you. I am SO glad in my search for health insurance I didn’t join the AGA.
Lol, deflect, attack, and avoid the issue Michael. It’s still about an AMC improperly directing HOW an appraiser is to perform their work. My time is limited Mike. If you have nothing more to add to the original issue, I’m done with you.
The only one deflecting and avoiding the issue is YOU. I’ve answered your questions 16 different ways and you’ve ignored what I wrote because I won’t sign on to your little crusade.
-It’s not improper
-It is not a USPAP issue
Period. Just because you don’t AGREE with that does not mean it’s “avoiding” the issue.
Now, I usually just chalk this up to “the guy from AGA is stirring something up again” but I feel so strongly about this I have written to the Appraisal Institute encouraging their leaders to provide a counter-balance and voice to regulators AGAINST your point of view because voices like yours are not the prevailing wisdom of the appraisal industry at large and your misguided efforts are going to cause appraisers to be responsible for inspecting and identifying things they should NOT be responsible for. If your time is so “limited” then stop responding to one appraiser from Kansas and get busy with your little crusade.
NOW we’re done.
Blah, blah, blah ! Y’all both need to twist up one of them hemp plants, light it, and take a couple of deep breaths and chill the ” f ” out !!! Have a great holiday weekend !!