I’d also add that, if USPAP is unconstitutionally promulgated (for which strong arguments exist), most appraisers probably wouldn’t like the easiest fix: present federal financial regulators and HUD would make it. Or, as was proposed in legislation by Maxine Waters, a new federal agency would be responsible for it.

And; Missing the IVPI proposal yet?
https://www.workingre.com/wp-content/uploads/2013/08/IVPI-Proposalfinal.pdf

Grandma got ran over by a reindeer.

In today’s new and unimproved appraisal atmosphere, any appraiser that does not “hit the number” is open to detrimental consequences.

Buyers, Sellers, & Refinancers – The U.S. Government from the top down have provided the media and the public in general with so much toxic misinformation and encouragement that any appraiser doing their job, a job that can lead to lower values than expected, can now be turned to HUD itself, or a state appraisal board for racial bias. So, why bother!

Realtors – They are not your friend. Hit a number lower than the contract price and they go to the lender or even the AMC and demand you no longer receive appraisal assignments. It’s called Blacklisting, it’s illegal, but those that regulate you don’t care! So, why bother!

Fannie Mae & Freddie Mac – They say you’re needed, but…they really hate you! They are systematically trying to eliminate appraisals altogether. Fortunately, there is a US Code that requires federally related transactions be appraised. Unfortunately, Fannie and Freddie have been provided significant latitude as non-government agencies and purchasers of mortgages. In fact, in 2023, Fannie Mae published documentation stating an appraisal was the LAST alternative needed of the five (5) possible alternatives. And…the government did and said nothing. So, why bother!

Further, Fannie and Freddie have now elected to censure your appraisal reports. Any word they have dreamt up as being racially bias is now red flagged. And by the end of this month (Jan 2024), state boards will start receiving those infamous Fannie Mae “Tips”, which will in most cases become state investigations.

U.S. Government/Regulators – They do not care about you, and they are not on your side. In fact, appraiser/appraisal reform was in Joe Bidens presidential running platform. Once elected he immediately started the “witch hunt” via the Housing and Urban Development (HUD) agency, appointing them the new “witch hunters”. HUD’s Secretary Marcia Fudge is the head witch hunter, along with her accomplices from the PAVE movement, which by the way consists of a number of agencies also in the appraisal regulatory line.

So, while there are only a few of the 80,000 appraisers now in the line of sight of HUD and the state regulatory boards, as long as the new normal is reporting the appraiser when you don’t like the value continues, why bother?

You sir have earned a standing ovation.

Value came in short? Racist.
Over-appraised that house? Your black-listed by the GSE’s, get fined/state sanctions, and have the pleasure of buying the loan back.

They all bitch about the lack of appraisers, appraisers leaving the industry, lack of trainees, and appraisers refusing difficult/rural assignments. I wonder why?

But a few more DEI classes and USPOOP training will fix you silly appraisers.

Thank gawd for private and bank work.

In other words appraisers being investigated by HUD for USPAP violations can sue HUD for violating the due process protections of the 5th amendment and equal protection clause of the 14th!