Thank you Lori. Interesting. Educational. Complex. If you thought complying with the mish mash regulations for appraisal oversight was difficult. Take a stab at administrative procedures for extra credit. It would be doubtful to expect the lurking bureaucrats haunting the state halls and to know all the details either. They’re in place to milk the golden cow and as far as I’m aware, there are no special continuing education requirements focused on procedural compliance, review, adjudication, applicable authority, etc. Like most government efforts these days, they just enact what they want, rules and constitutionality are hardly ever challenged. “Come out of her my people.”

https://en.wikipedia.org/wiki/Administrative_Procedure_Act_(United_States)
https://uscode.house.gov/view.xhtml?req=(title:12%20section:3335%20edition:prelim)
https://uscode.house.gov/view.xhtml?req=(title:5%20chapter:5%20edition:prelim)%20OR%20(granuleid:USC-prelim-title5-chapter5)&f=treesort&num=0&edition=prelim

From the third link: Applicable to this appraisers drawn out expenses?

§504. Costs and fees of parties
(a)(1) An agency that conducts an adversary adjudication shall award, to a prevailing party other than the United States, fees and other expenses incurred by that party in connection with that proceeding, unless the adjudicative officer of the agency finds that the position of the agency was substantially justified or that special circumstances make an award unjust. Whether or not the position of the agency was substantially justified shall be determined on the basis of the administrative record, as a whole, which is made in the adversary adjudication for which fees and other expenses are sought.
(2) A party seeking an award of fees and other expenses shall, within thirty days of a final disposition in the adversary adjudication, submit to the agency an application which shows (continued)

USPAP Standards Rule comment 1-1
(b) not commit a substantial error of omission or commission that significantly affects an appraisal;
(c), perfection is impossible to attain, and competence does not require perfection.

So who is on first?

This time, the victim is a veteran ~ a Marine. Every appraiser should write and thank him for standing up to scofflaw and anticompetitive board practices.

If you feel the need to do something more, inquire with your respective state auditors and find out if the appraiser board is in compliance with Administrative Procedures and if USPAP is even codified. If not, take the discussions further and higher.

Louisiana recently passed legislation that allows licensees and citizens to petition for audits of scrupulous and subjective rules. After what FTC and LA showed us, it truly shocked me the ASC and states doubled down on barriers to entry and scofflaw.