You touch upon the original purpose of representation, lawyers, whatever they may have been called in that era.

You can’t legislate honesty into any process but you can effectively dissuade quite a bit of immoral activity by way of effective deterrence, usually in the form of justice through fines or incarceration.

The problem with regulation of lenders these days is that nobody goes to jail, fines are not based on income, resulting in a climate where it’s profitable to defraud people and the motivation to do so persists.

If there is one important take away I’ve learned from being this close, is that debt is dangerous and there is no such thing as a ‘safe loan’.

American citizens would be best advised to devise their own game plan to utilize mortgage lending services only as necessary, in order to achieve the fastest route possible to a complete unencumbered ownership position. Well, as unencumbered as may be possible given pervasive over taxation sweeping through our society as the size of government reaches epic new heights never before seen on this planet.

It’s like the trainee license will now become its own permanent quasi licensing type.

There might be an upside to downgrading our license status if hybrids really do take over. What do you suppose the requirements for that action would be?

I’ve got a meme for that. LOL.

Just swap ltv for hybrid something or another…

Naturally pollinated v hybrid. Mules are hybrid, many brands or corn, maze, or peas are hybrids. Typically hybrid are specialists, expert at only a limited task. A mule, or henney is the product of a jack and a mare, or a stud and a jenny. They can’t breed themselves, specialty corn can’t reseed itself. Hybrids are the product of mass productions.

Appraisers are broadly educated economically thinking independents who take on special tasks. Our values are in THE CLIENTS we serve. High volume assignment are still individual assignments negotiable (collectible) individually.

Since the times if the Greeks, since the times of the Romans since the time of Christ. No One, NO One has been able the legislate honesty.

Attorneys have gone to jail, accountants, bankers, have practiced beyond conscience, as well as the clergy.

Our politicians make popularity by making new laws.

Does that make our profession more honorable or do we the practitioners.

Yes, states are looking to make field inspectors licensed. It is one way the States can regulate those entering homes. It also will eliminate the entire concept of having 3rd party inspectors. Who will obtain a license to accept a $15 job?

The inclusion of EXPERT reports has always been a valid appraisal process. It’s not a ‘hybrid’ appraisal.

Hybrids do not require and likely will never provide expert third-party assistance. They market themselves as having “robust” field inspections (whatever the hell those are).

I don’t require ambiguously parsed qualifications. I require competently performed field inspections by professionally trained individuals under MY guidance and whom also have a fear of recourse from their state regulators to discourage unacceptable short cuts or carelessness.

We used to call them ‘licensed trainee appraisers’.

The very concept that non-appraisers or appraiser trainees can credibly provide relevant inspection data for an appraisal is beyond ridiculous. Has everyone forgotten what trainee licenses were originally intended to be for?

It was the lenders that PROHIBITED our using them for field inspection.

It was the regulators who limited the number of them we could train at any one time – directly limiting our ability to incorporate them into any reasonably sound and profitable appraisal company scenario.

It was also the regulators that started telling would be trainees NOT to obtain trainee licenses! (CA BREA), but to wait until they were fully licensed so they would not be subject to BREA oversight (while their supervisors were!).

ALL levels of real estate appraisal should require a licensed or trainee licensed appraiser that is subject to state enforcement. The same applies to any company claiming to ‘manage’ appraisers. The persons assigning work; reviewing work and deciding on fee increase or turn time extensions should all be licensed in the state where the assignment is.

They cannot ‘manage’ that which they don’t understand-including USPAP and state legal requirements.

Think about that Advocate. Appraisers are already licensed. Now states are thinking of a new separate category license for ‘partial appraisers’?

The very concept that non-appraisers or appraiser trainees can credibly provide relevant inspection data for an appraisal is beyond ridiculous. Has everyone forgotten what trainee licenses were originally intended to be for?

It was the lenders that PROHIBITED our using them for field inspection.
It was the regulators who limited the number of them we could train at any one time – directly limiting our ability to incorporate them into any reasonably sound and profitable appraisal company scenario.
It was also the regulators that started telling would be trainees NOT to obtain trainee licenses! (CA BREA), but to wait until they were fully licensed so they would not be subject to BREA oversight (while their supervisors were!).

ALL levels of real estate appraisal should require a licensed or trainee licensed appraiser that is subject to state enforcement. The same applies to any company claiming to ‘manage’ appraisers. The persons assigning work; reviewing work and deciding on fee increase or turn time extensions should all be licensed in the state where the assignment is.

They cannot ‘manage’ that which they don’t understand – including USPAP and state legal requirements.

John, determination of whether a room is a bedroom or a den based upon local codes and use custom IS a professional opinion. SF based upon measuring IS a professional appraisal, architectural or engineering opinion. Doing it correctly requires professional knowledge of what is or it not living area. Determination of either neighborhood or competitive market area boundaries is also a professional appraisal opinion. Condition rating is a professional opinion.

Lastly, knowing the specific background and qualifications of a field inspector is critical to determining whether they may be competent.

The form and format of the 1004P MAY potentially be made credible.
The form and format of the Mueller Reports currently making the rounds, ARE NOT credible…to the point of being likely to induce or promote fraud.
The form and or format of the ClearVal products and all similar products are NOT credible, and like the Mueller reports are highly prone to fraud.

Pretending such formats from so called “settlement services” companies is misleading to the public. There is no ‘negotiation’ of scope. They are a take it or leave it type assignment.

NONE of the latter credibly provide reliable results.

A 1004P may fall into what you describe. NONE of the others currently being broadly marketed do. They are garbage, and should not be performed by anyone calling himself an appraiser

I’m sure Mr Dell’s last sentence was sarcasm.

But, it needn’t be! Let’s build on it. USPAP at TAF’s urging should install another SR, this time for Inspections. Poor, sobbing, thwarted Inspection has been too long left at the curb by USPAP.

This will take time, perhaps by SR78 and AO322 we can have directions on how to do inspections: for ex, No Vans, golf shoes OK cause they have good gripping; no aluminum flex ladders (electric danger); OH, and ‘alternative’ evaluations for below threshold reports are excused, because, well, you know, the lenders, AMC’s, TAF, and what have you think they should be excused….and below threshold properties are purchased by trash that don’t spend a dime on really important folks like congressmen.

They may view this as the new cash cow for the State. After all, they will be making a killing with the fees from USPAP violations. So much for protecting the public. The talking heads now say it’s okay, don’t worry, be happy. Until the loans go into default, or the Realtors, buyers and sellers start with the complaints over the appraisal. The question will be: How can he say my property is worth $***,*** when he never even looked at it? The answer from the regulators will be: He does not need to look at the property, but don’t worry we will get him on something else. We need to investigate that appraiser, pull his work files for the last 12 months and let’s see how much we can get out of him. 2 – 5 more years and I am done.

I listened to that meeting about hybrids at the DORA office, through the minutes you posted. None of the decision makers did any homework and just fell back on their standard, all rules apply to the appraiser line. People whom could have protected the public trust, not even bothering to look into the issue and instead accept a 2 minute summary from a single person whom inadequately described the issue, regarding the influence of an entire lending community whom are pushing forward with these programs by the hundreds of thousands of instances. Clearly, the decision makers are not on the front lines actually completing mortgage lending work like we are. They could have at least printed some of our articles here. The answer to hybrids is already located in the QA section of the ethics book, really?

My assignment was for current value in trade. My report treated the cost approach as an useless academic exercise. There were like sales and rents, which were identified as comparable. My report mentioned the economics of the first report and the studies made and made use of those economics. My Values were supported by my report.

HYBRED?, or completed as contracted?

ALSO some time ago VA accepted an application for a loan on a equestrian rental home and business on ten acre citrus grove. I measured the 1925 house, counted the trees, evaluated the irrigation system and discussed the source. However the barns, corrals fencing, equipment were leased and under a contract which I included the report.

Hybred? I did not create a summation of the RE and Leases

The lenders have their obligations as do the other contractors. We make our contract going into the job, not making excuses for the job once done.

We had those obligations before licensing and due to past and current laws we still do

So they appear to be saying it’s just fine don’t worry, but when the loans go into default, the hammer will come down hard on the appraisers, by the very same people who are basically now saying “whats the issue.”

FNMA form 1004P looks just like the current URAR, I will not be doing these new reports for $125.

FIRREA directed TAF to establish uniform license requirements and MINIMUM standards for real estate appraisals performed for federally regulated transactions. Despite a lot of gratuitous changes over the years, the standards worked reasonably well until the Scope of Work Rule encouraged everyone to reinterpret the other meanings and requirements of USPAP under SR1 and SR2. Now, these reinterpretations and selective parsing of English have resulted in products that by their very nature are at best misleading.

Partly to blame is the adoption by some states or alternative standards (read that to mean pretty much do whatever you want as long as it’s generally addressed in scope of work).

The ONLY acceptable solution to the so-called hybrids or third party issue is to require USPAP to be followed to the letter, and that ALL parties to the preparation of ANY appraisal (hybrid or otherwise) be licensed as appraisers. Still need ‘third party’ inspectors? Fine. Use trainee appraisers and let us decide how to train them. They also should be required to have trainee licenses. Some states trend to telling trainees they are shielded from complaints by remaining unlicensed is a mistake (CA-BREA).

States should seriously consider a return to laws that forbid anyone that is NOT a licensed appraiser from opining about value, regardless of what other euphemisms are used to describe it. Either protection of public trust means something…

Or, it doesn’t.

Collateral risk Is the problem. The feds have the risk the lenders DON’T