True. We foolishly want to think the meeting had anything to do with the topics and views put forth.

The SOLE PURPOSE of the hearing was to cast Dodd Frank in a bad light on one side; and to defend it mindlessly, on the other.

Peter the American Guild of Appraisers asked that specific question of the ‘behind the scenes’ folks that organized the hearing guest list. According to them two of the speakers were invited for no other reason than they are an ongoing nuisance to the Committee. You decide which ones.

We are now on the ‘list’ for inclusion in future discussions. We’ll see.

Testimony was largely from the perspective of self serving interests. Garber, who is the paid flack for the Appraisal Institute was there to promote the AI’s desire to have special exceptions carved out from existing standards for the limited benefit of a very few of their MAI members to the detriment of the SRAs and other residential associates, as well as those MAIs that don’t play the AMC alternative “national appraisal firm” game.

NAHB was there to flail meaninglessly at windmills. The solution to their concerns were the easiest to resolve but they insisted on playing Man of La Mancha instead. They don’t need a universal “Tidewater” rule like the VA…all they have to do is train THEIR sales reps to ASSUME more support is needed for values and to provide it up front…instead f pretending to be too cool to be bothered with appraisers.

Joan Trice (and Garber as well?) want an NMLS type licensing system where appraisers can hop around and appraise anywhere they want…state to state. No inherent competency issues there, right?

Maybe it is time to revisit FIRREA in its entirety again. At least the portion dealing with appraisal. Certainly standards that seem to have to be changed every two years can’t be very good standards to begin with, can they?

Let the mortgage and international banking industry decide what IT wants; and then let US decide what the standards and principles of appraisal are to be. S&Ps that do not change with every breeze just to warrant selling new USPAP courses.

But STOP telling us that the integrity of the process is important, and then undermining us with the very next set of regulations. Either WE are the professional appraisers or some FNMA or CoreLogic, First American database is.

THEN lets hope someone actually requires state regulators to learn and follow them.

Stay focused Jr!  You’re such a joker.  LOL.

Per the silver deal.  Well, whatever, buy a hundred bucks worth at a time but don’t over due it.  It just sits there, begging to be stolen.  I don’t have much but support the theory.  Gold is not very fungible, don’t need to risk mis placing a thousand dollar coin nor do I have time to worry about that.  If the economy collapses silver will merely have long term benefit like a hedge purchase.  Ingots are good for barter in theory but I’m not going to pay a buck over spot per ingot, it’s a racket that one.  It may take another congressional act of reconstruction for the tangible benefits to be realized as anything but an investment metal.  It’s the tying of silver to the dollar to stop rampant inflation tied to planned obsolescent consumerism trends that matters most and would have meaningful impact.  You can’t reform the irs with the fed unregulated and a fiat system where the irs functions as the debt recapture mechanism.  You don’t know what you don’t know.  That’s what they told me on the internet and I believe them.  For wealth, I have very little but also have a positive position because I accept almost no debt.  If things fell apart, I’d outlast the majority whom have all that supposed ‘wealth’.  If I was born in your day, I’d have made a true killing.  Then again, I’d probably have gone with the flow since my knowledge today comes from the antagonistic position many millennial like me were forced into.  Actually they call me a gen X’er, but whatever, labels. I’m only 40 something you know.  As long as I can eventually own this home completely without a mortgage, everything will be fine.

https://youtu.be/ZKLip7Q_Y0s

It’s easy to be stuck in this box.  Yes, I am a conspiracy theorist, but most of the points are not theory, they’re fact.  I’m better described as a conspiracy factualist.  This industry is experiencing the same influence as many others;  ‘compulsory planned obsolescence’.  You don’t know what you don’t know, but I warn you;  Once you’re educated you can not unlearn what you have learned.  It’s always easier to demonize free thinkers than to actually have to answer and debate the facts.  Want to talk about flat earth theory?  Why don’t we stick to industry and profit instead, something not theoretical, but completely factual and well documented, at least for now.  Welcome to your modern view of consumerism, most Americans would be surprised to find they’ve been played by free markets their whole lives.  Reasons why I love the goodwill and rarely purchase new.  Reasons why I refuse debt based consumption.  Reasons why hedge purchasing matters.  Reasons why you should not even have to hedge purchase in the first place.  “He was back woods, back wards, use words like yes mam and no sir.  He didn’t want it if he couldn’t make it with his own two hands.”  Growth, the holy grail of our economy. Yes it’s true, I’m still using the HP Laserjet 3200 w/ graphite 92A cartridges. I buy the cartridges which print 2500 pages for 20 bucks a pop on ebay these days. Get them while they’re still available. I’ve got a dozen right here in front of me. Still talking on the 1985 made in USA bell phone and still don’t buy into cellular and wifi services. I’m not voluntarily subscribing to planned obsolescence of my wealth. I called this one about planned obsolescence a long time before I ever even learned the facts. But hey; Truth is like a lion. Set it free and it will defend itself. Thrift matters. Repeat after me; Debt is bad, thrift is good. Repeat to infinity.
I’m not sure the link worked, will repost link.

Sometimes you guys make comments that I completely agree with. Should we own gold? Heck, I do not know. When I was a kid riding my bicycle in the neighborhood my friends and I would pick up soda pop bottles from the ditch. If you had three empty bottles you could trade those for a coca-cola and a “large” butterfinger candy bar! On Saturday morning you could get into the movie with six coca-cola bottle tops. My dad had a coke machine in his business so we had enough bottle tops on Saturday morning to take all the kids in the neighborhood to the movie! Have you dudes priced a trip to the movie lately. My lady and I went recently…two senior tickets, one large popcorn, two drinks….beat the ears off of a $50.00 bill!

Now folks think they should earn $15.00 per hour to flip a hamburger. I worked at the Dairy Queen for $0.40 per hour while in high school. I also shined shoes and mowed grass. I talked my father into helping me buy a Suzuki motorcycle. He had never been on a motorcycle and had no clue. This was the X-six scrambler and would go from 0 to 60 MPH in six seconds. I surprise myself that I am still alive!

My whole point with this rant is that appraisers are for the most part under the control of the lending industry. It is they who select who will work and who will not. These folks lend other peoples money for a slice of the pie. Appraisers are just a cog in the wheel that assists them in earning their fees. They absolutely do not give even a tiny damn as far as public trust or other similar bull. If the appraiser does not assist in this process, the appraiser will be toast. I hope those that think otherwise have found other employment.

From what I can tell those gurus in charge will begin to reduce the requirements to become an appraiser until it is to the point of $0.50 and two cereal boxtops. Get REAL….these lenders have already told you the value (by sending the sales contract) They just want your signature and E&O to earn their commission. Nothing else matters at all!  A new year is coming up…why not try keeping your money in your pocket for 2017 and not sending it to all of these parasitic groups that are creating problems with your career? No problem…just keep your money in your pocket and these parasites WILL go away! Good luck to all who continue to play this game!

Well it’s all a cover you know. Without the various bureaucratic time drains, we’d have to actually face up to the root cause issues. This is the Ron Paul argument, the government can never grow big enough to effectively regulate private lenders. This is the historical references to lenders being more dangerous to our liberties than standing armies. This is the reason why currency must be re tied to gold and silver, and the fiat system let fail. Sure, but let’s just revisit the appraiser deal, that should keep them occupied for a few more years. If lenders were lending their own money, they’d fight over competent appraisers.

“Reason to own gold number 287. Many people do not know that the bank rules have changed and when you deposit money at the bank, you are merely an unsecured creditor of the bank. That means if the bank goes under you get paid less.” Rather than play by the rules, major lenders changed the rules. ‘Your’ savings is merely a credit to the bank and your customer position is now officially that of an unsecured creditor. Basically if you make a deposit or leave money at most banking institutions, that money ceases to be yours. Even keeping money at banking institutions these days is possibly risky. And also there are many new rules regarding limitations to withdrawn funds. There will never be another bank run per say, because banks simply shut the windows down in a time of crisis and limit actions of ‘customers’, or should I say, the creditors. It’s all legal now, the mechanism to stop all faucets of possible bank runs. Also, lenders worldwide have floated austerity measures in various increments. Austerity is the stop gap and it’s been used recently in the European areas. Not only can they stop the withdrawals, they can allocate ‘your’ funds to stop liquidity crisis on a permanent basis. Poof, it’s gone.

To the laymen whom is reading this and may not understand, it’s quite simple; Lenders have trillions of unfunded liabilities, especially through derivatives market. They’ve been caught manipulating silver markets and libor rate for decades now. Exposure finally came around and on par, nobody went to jail. In a time of crisis no money can be withdrawn and all money can be re allocated to the banks coffers permanently to stop liquidity crisis. So forget about the bail out, that was so much work, the bail in is now in place. As a rule of thumb never challenge a lender to gamble, because the federally insured banks are basically professional gambling houses. Major bucket lending institutions, if you will. That’s what they say on the radio, and I believe them. There is a lot of meat in the argument to wind down FNMA, audit the FED, and let free markets correct this constrained market manipulation. aka, the revolving door argument.

The beat skips on.

http://patriotarchives.blogspot.com/

The unfunded liability of retirement programs is shocking though, one big illusion held up by a thread. It’s important to note that many of the state pension programs are tied to libor, and backed purely by fiat. Only the older people talk that way these days, because most of us younger persons know there will be no social security or retirement package except what we make for ourselves. Reasons to own your home and never refinance except to save time. I agree with you, the regulators are turning to the people whom stirred the pot in the first place. A new career for me you say? Well, this profession has certainly challenged the skill sets and now I could move competently to a wide variety of other businesses. Don’t discount the little guy in this industry just yet, we all fill pretty big shoes just to be here.

If the truth be known Ralph, it’s not that these groups and governmental agencies “have no clue” but rather that they don’t give a shit about rebuilding the world of the appraiser after dropping their 100 megaton bomb on the industry in May of 2009.  Do you realize how many billion of dollars in revenue banks have reaped from the appraisers pocket since 2009 via their AMC subsidiaries?

https://www.youtube.com/watch?v=w2ATQFVrbJ0

Personally I have zero problem if someone wants to back me on a pass line bet on the next roll of the dice. Lets see they want to back me to the tune of $1,000,000. one roll of the dice! Gee…what if they bust their ass?  (and eventually they will) Does not matter as it is their money! HOWEVER…what if it is a bank idiot using depositors money? A totally different story! These bastards should spend some time in prison if they gamble with depositors money. Maybe get their ass kicked while there!  There is a difference!

Freddie/FNMA are already rolling out appraisal free products for re-finances and honestly who can blame them, with many areas of the country experiencing 1-2 month turn times due to the appraiser shortage, there is no way the people holding the $$ are going to keep losing deals and rate locks, due to appraiser’s being booked out 2 months. I know all of you think you need a full appraisal on every order, but in homogeneous areas of the country and in tract sub-division land, the data models available for those places are getting very accurate and if a borrower has good credit, income etc, and the AVMS are in a tight range, it’s just a lending decision, based on risk analysis. For those of you in complex market’s and on the coasts, I think there will always be a need for full appraisals. Just how I’m reading the Tea Leaves. Good luck out there.

Just think when we ever have a group that wants to discuss appraisals/appraisers these idiots do not even include any of the appraisers who are working in this field each day. They want to hear from folks that operate AMCs or Expos, or newsletters or such bullshit! In other words the people who have created the problems are being asked to solve the problems. Well those of us who are old will simply retire…the young ones will (and should) move on to another career. Not sure how these AMCs can do appraisals without appraisers but it will be interesting to see!

Awesome Mike. Yes, self regulation and what amounts to racketeering is the norm not the exception these days. Big data is controlled by fewer people. Therefore mistakes have a larger scope of systemic influence. We can’t have checks and balances if one man or one company plays god to the whole system. 

Corelogic should be broken up under monopoly statutes. C&R, the mythical unicorn that never delivered. I told everyone from day one, I’d fall over backwards and spew coffee if a single lender ever got that 10k fine. AI rules, the toothless tiger. See addenda continues to be accepted code word for outright cheating and nobody is going to stop us. This ship of fools has sailed and there are more vendor managers than vendors themselves. Government has failed in their duty to regulate safety into the GSE guarantee programs. That’s what this is all about, let’s not forget. Time to wind down fnma and let the lenders hash this out in a free market setting in their own board rooms. If lenders shouldered their own risk and had a 1/1 ratio on capital reserves vs capital lended, this RICO level manipulation of markets would not happen. That’s how it works for the rest of us, a dollar is not 20 dollars of lending potential, it’s simply a single dollar. You can bury it, spend it, or invest it. 

Back to the basics and off with their heads!

Wayne I’ve travelled in the Marine Corps; and when I got out. I sailed on a small boat to Acapulco from California. I’ve sailed and dived from Cape may NJ to Icacos Puerto Rico; and on the Chesapeake, Severn and Patomic.  I lived on boats in California from 1980 until 2005; and my old diving buddy retired to Belize.

I have my memories. I want to leave a worthwhile legacy for the next generations of appraisers. I already consider all appraisers that do honest work to be my friends.

Our profession wont fix itself. So to all, create those memories Wayne speaks of…but save just a little bit for the profession that helped you make them.

A proposal WAs made for a national appraiser license similar to NMLS so that appraisers could appraise across state lines with little or no restriction (or enforceable area competency). Mr. Garber conceded it may not be applicable for residential appraisers where local knowledge is critical but commercial appraisers weren’t bound (as much?) by those.

Ms Trice supported the NMLS style licensing.

Neither addressed the impact of such licenses on that old belief about real estate. The three most important things are location…location…and location.

Just because a property produces income does not mean investors for that specific property (or type) accept the same rates of return in New Jersey as they would for Kansas or Alaska. State laws that could impact value in California are not necessarily the same as in coastal Florida locations.

Then again, big data doesn’t like to get bogged down in too many details.

My impression was that there were two simultaneous hearings by the same people in the same place.

There was the actual televised hearing with disparate prepared speeches; and then there was the real underlying reason for the hearing. The partisan battle to eliminate Dodd-Frank.

I try very hard to take a non partisan approach to the issues facing appraisers when writing about or for AGA. Obviously AGA is a union organization, though as I’ve said many, many times, we are not your grandpa’s old union. We seek win-win solutions.

Its important that I also disclose (as I have in public appearances before TAF and APB), I personally happen to be one of the extremely few Republican Union Organizers in America. Those that know me or my history writing here know why I joined an appraisers union. I only remind readers of this so that any will understand my views are purely objective and not partisan based. If I could overcome my aversion to traditional unions to organize one, then I submit I AM capable of unbiased analyses. Readers must judge this for themselves.

There is very little in Dodd-Frank that (my) GOP objects to that is important to real estate appraisal. We had appraiser independence requirements long before Dodd Frank. They wont go away whether DF does or not. Frankly about the only thing DF DID do for appraisers is create the illusion that reasonable and customary fees would somehow become enforceable.

We all know what a bad joke that is! Only 38 states of 55 jurisdictions have passed ANY type of AMC regulations to date and very few of those have passed clear or enforceable C&R fee laws (Virginia; NC and LA tried). DF merely gives states the right to ignore C&R IF they choose to. There was never a credible enforcement mechanism.

So, it will not truly affect appraisers if Dodd Frank were to be rescinded in its entirety. We’d still have the battle to get federal support for ENFORECEABLE reasonable fees (can we just drop the pretense of “customary”?). Working for less than a fast food worker EVER, is not ‘customary OR reasonable’!

Where DF DOES become an issue is in the ongoing partisan war between the Democratic Party and the Republican Party. DF created the CFPB which does appear to have benefitted regular taxpaying American citizens and investors already. Case in point is Wells Fargo and it’s well publicized FRAUDULENT treatment of customer accounts. DF does benefit taxpayers. Whether the same protections could be done differently is open for discussion. Those cases are not appraiser issues.

CFPB also is supposed to be the place where certain limited appraisal/appraiser independence/ consumer appraiser rights issues get handled but that system is so murky and disorganized so as to be useless. In my opinion, no benefit to appraisers exists so far.

We’d likely survive the loss of DF and CFPB; though as Committee Member Green pointed out, DF was not and is not a cause of the appraisal problems in America today. It merely fails to resolve any of them.

It’s erroneous for any to say there were no appraisers on the witness panel. Mr. Park of ASC is. I believe Mr. Bunton is as well. Mr. Park has been a Member of the AI for over 25 years. I believe he properly maintains his independence from purely AI-benefit issues. I’ve spoken with him several times now and I believe he is beyond reproach in his actions with ASC despite the grilling he was subjected to by the committee. We all have to remember his is a highly sensitive position politically.

Mr. Bill Garber representing the Appraisal Institute does not appear to be a licensed appraiser anywhere unless it is under a different name. I checked the ASC Registry for Bill and William and he is not found. So we are left to wonder whether despite the title if he is anything other than a paid lobbyist for the AI?

By the way, the AI claimed to be the largest appraisal organization as if that is some kind of inferred representation of ALL appraisers interests. I’d like to check the ASA rosters before conceding size superiority of the AI in America. Though they may (or may not) be the largest if worldwide membership is considered. My point is that there are over fifteen (15) other nationally recognized professional appraiser peer organizations PLUS over two dozen State Appraisal Coalitions representing appraisers. Why were none of these included?

What about the National Association of Realtors? Clearly THEY are the largest real estate trade group in America. NAR also has its own appraisal disciplines and designations.

Let me repeat that. WHY WERE NO APPRAISAL ORGANIZATIONS included beyond the one with a paid lobbyist and their own *self serving agenda? (Ref: *promotion of alternative appraisal standards for limited use by their members-see CA AB624 and similar bills passed/proposed in TN, IL and TX).

The battle between the AI and TAF is no secret. So it’s no surprise that they oppose the Appraisal Practices Board created by TAF. Let’s not lose sight of the fact that they were removed as sponsors of the TAF or the reasons.

AI serves a very specific & very small segment of appraisers in America. They have many respected educational offerings. They are not the only ones that do however. ASA & NACVA are as highly respected in their own right, as are many of the other nearly three dozen UNREPRESENTED appraiser peer and state professional associations absent from the hearing.

Mr. Garber’s written proposals were not presented to listeners beyond his stated belief that the APB should be disbanded, and that cheaper, big data driven alternative appraisal products and standards are desired by the AI.

Ms Trice is also not an appraiser (no current license on Federal Registry). Her voiced views sounded very reasonable. The devil is of course in the unknown details of the proposal she submitted that was NOT discussed or summarized in the hearing. Ms. Trice is known to have represented or advocated for the interests of AMCs, to the detriment of most appraisers needs, but let’s keep an open mind until we hear all the details of her specific proposals to the Committee.

Ms Wagner of Mountain States law largely cited ancient history – events that predated the collapse of 2008/2009. She referred to (inferred) recent loan modifications related to high rate predatory lending but no one has offered the type of pick a payment, option ARMS she described since 2009. In any case, her concerns serve as an ongoing caution. She too opposed big data driven alternative products that are less reliable than real appraisals.

Mr. Brady of NAHB had several legitimate appraiser concerns but none that rise to the level of requiring congressional oversight. He proposed something similar to the VA’s “tidewater” system where if a value issue is noted in the development of an appraisal, the appraiser would stop and contact buyers and or sellers to discuss it (no pressure there, right?).

The point he missed is that builders sales reps ALREADY HAVE THE ABILITY for that type of input! These are no individual consumers with limited experience in real estate that require special protection as some veterans might. They are professionals “in the business”.

They have their “tidewater” opportunities BEFORE the appraisers ever show up to do the appraisal! ALL they have to do is their jobs. That’s it. They could follow the NAR Code of Ethics regarding appraisals. They could LEARN to have information available to support their prices BEFORE the appraiser completes his or her work. They COULD get loan funding commitments from lenders in advance as builders did for over 40 years before HVCC. IF he is serious I invite him to reach out to me through the AGA. His concerns are the easiest to solve.

He had a valid point about appraisers not always being qualified to do new tract housing appraisals. Until C&R fees are paid, that will remain an issue. There are already laws in place that say complex assignments must be done by certified appraisers. New construction by its very nature constitutes ‘complex’ appraisal until such time as open market resales are generated and most builder defect warranties have lapsed.

I know many licensed appraisers that CAN do great work on these, but that’s not who the AMCs hire to do them. Even if certified appraisers were required, many will still lack adequate experience with new developments.

IF NAHB wants expertise, then they should be willing to PAY for expertise…not appraisers that still brag that they can complete two or three appraisals a day start to finish all by themselves.

The committee’s conclusion as to why there is a ‘shortage’ of appraisers is seriously misleading. I sincerely hope it was not a window dressing Congressional meeting to provide cover for a foregone conclusion that was predetermined behind closed doors.

Not long ago, TAF (AQB) proposed and modified requirements for entry level appraisers and those seeking higher licenses. Many from the AI asked rhetorically why anyone would support  “lowering” standards by eliminating college degree requirements (that were add on requirements; just like APB is an add on). Now I ask THEM the same question. “Why do the AI, AMC Trade Groups and certain Committee Members want to lower appraisal standards?” If ‘Big Data’ were so reliable, then how come it couldn’t get the recent election polls or results right? How come it cannot reliably predict the stock market? “Big Data” has been getting it wrong for decades now. Modern computers merely help get the wrong answers faster.

I understand that there is currently a survey with (so far) over 500 appraiser responses (Mark S. out of Georgia) and the number one concern remains adequate fees and the manner in which they are paid.

Before forwarding any recommendations to the full FSC or Congress I hope the sub committee will make an effort to assure greater outreach to ALL stakeholders.

That includes appraisers.