Appraisers Take on Washington DC
Hybrids were a big topic & many regulators are concerned about their compliance…
Independent Fee appraisers representing 15 different states were well represented in Washington DC this past weekend. Appraisers from Virginia, North Carolina, South Carolina, West Virginia, Ohio, Louisiana, California, Illinois, South Dakota, Michigan, Utah, Rhode Island, Delaware, Maryland and Washington State joined together in DC for several gatherings. To sum it up simply… Positive Unity among all.
On Friday, three members of VaCAP attended the Appraisal Standards Board Meeting. This meeting was live streamed, so hopefully you were able to watch live. Lots of discussions on the proposed changes to the 2020-2021 USPAP. There are a lot of changes… 90 pages to be exact! VaCAP encourages each of you to take the time to read through the exposure drafts (there are two). A third exposure draft will be coming out in December.
The proposed changes are substantial in some areas and minor tweaks in other areas; however, the structure is changing. Be on top of this and submit your comments when the third exposure draft is released. Do not take this lightly, realty think it through!
Two members of VaCAPs’ Executive Board attended the Association of Appraiser Regulatory Officials (AARO) Conference. The event had many appraisers, amcs and regulators present. Appraisers have become more involved with AARO over the past few years and have been an integral part of the conferences. This was a 4 day event and very informative.
The Professional Organization Committee, chaired by Karen Emerle (ICAP) presented a program on education reciprocity among the 55 jurisdictions. Charlie Gress (OCAP) was a key presenter. Both Charlie and Karen are active members of the Network of State Appraisal Organizations (NSAO) Congratulations for a great presentation!
To recap some other highlights:
Hybrid Appraisals were a big topic – Many Regulators are concerned about their compliance with their state statutes and are starting discussions on them. The definition of an appraisal in each state seems to be a big issue in allowing a third party to complete the inspection. Some AMC’s are also seeing these products as problematic for everyone. Fannie Mae presented their justification on why they are pushing hybrid appraisals. A look of disbelief was on many Regulators faces. It is if they were asking “how could Fannie Mae be so far off track.“
AMC National Registry: Regulators and AMC’s both are attempting to determine best practices on compliance. At the moment, it appears an honor system will be used. Some states have started auditing amc’s and are establishing their own best practices. This is going to be a work in progress for many years it seems.
PAREA-Educational Training Modules– TAF is working on virtual training modules to give appraisers more diversity on training. This is going to be a great tool for new appraisers coming into the profession.
Standardization of CE Approval among States- the idea is to reduce the burden on each state to approve each CE course. If the standards were consistent among the states, once a state approved a course, other states could approve as well without a re-examination of the materials. A huge benefit to Regulators, education providers and appraisers.
Best practices was a central theme of AARO. Regulators, appraisers and amcs working together for the good of everyone. Perhaps the most notable portion of the AARO Conference was learning how other states operate. Many we spoke with shared how they work closely with appraisal coalitions and other licensees to work together on the issues that arise.
VaCAP will continue to be part of AARO and other organizations in which we align. Thank you for your continued support.
VaCAP has come across two articles that are worthy of sharing.
The first article was published on AppraisersBlogs couple of days ago. It questions Alamode’s Smart Exchange being in compliance with state laws. Virginia, along with a few other states, are used as examples where there may be conflict with State Statutes if you use this program. Definitely worth reading even if you are not using their program. See the article here.
The other article was published in Valuation Magazine, an Appraisal Institute Publication. The article, written by Peter Christensen talks about hybrid appraisals and how they have triggered legal action against appraiser on the commercial side. This too is also worth reading. Thank you Peter Christensen and the Appraisal Institute for publishing this article. See the article here.
- We the People… - April 9, 2023
- Federal Valuation Agency Impact on Appraisers & the Public - July 22, 2022
- Is Georgia Going Rogue? - June 13, 2022
“Some AMC’s are also seeing these products as problematic for everyone”
It appears though that the vast majority are pushing these hybrids. Which amcs see these as problematic?
See, I’ve been saying this all along , get ready for them. AMCs don’t like them cause of the cost, they can’t Rob the appraiser .
AARO has no legitimate reason for existence. None. Official state policies are not and should not be decided by official regulators acting as individuals under the auspices of a private corporation that is not answerable to taxpayers and government oversight. Nor should those same state regulators be allowed to lobby as a private entity for changes to their own or anyone else’s regulatory requirements where they are perceived as having some level of governmental imprimatur or authority. Those are actions for elected state representatives – not appointed or salaried officials pretending to be private citizens.
Attending AARO conferences to identify what the regulatory ‘enemy’ is thinking or attempting to promote behind the scenes is commendable and prudent.
However, it is an egregious error in judgement for VaCAP or any appraiser to start treating AARO as a legitimate entity to be negotiated with. Suggesting we can or should have “AARO, Appraisers & AMCs working together” is utter nonsense.
It’s at least as nonsensical as regulators trusting AMCs behavior based on the honor system, after having had extensive evidence and court cases over the past 9+ years that “honor’ is an extremely scarce commodity among them.
Instead of playing patty-cake with AARO, it would be far more productive to ask each and every legislative body in the States why they permit official state policies to be decided upon out of view of their elected constituents and developed through a private corporation staffed by officials pretending to be private citizens.