Instead of addressing these issues, many if not most states are instead going after appraisals to impose more fines. They do this NOT to improve or maintain appraisal quality. They do it to backfill declining department revenues resulting from decreasing numbers of license fees.

More and more states are using “Factual Investigation” chimeras in order to circumvent an expectation that they will review & report USPAP compliance in accordance with SR 3 and SR 4.

State Appraisal “review” has become a process of legal “gotchas!” rather than professional appraisal reviewing in accordance with standards that we all know and understand (USPAP SR 3 & 4).

Appraisal has long been a profession that encompasses both art and science. Whether its the artful application of science or the scientific application of art,; or simply a variable mixed blend of both is up for discussion. What is NOT up for discussion (or shouldn’t be) is the current regulatory presumption that appraisal review can be replaced by purely academic ‘fact-finding’ with a prosecutorial bent.

No appraiser anywhere should ever be subject to disciplinary action on any appraisal that has not in fact been the result of a properly completed SR3 & 4 compliant appraisal review.

Until this specific issue is adequately addressed not much else matters.

cc: Other state or federal agencies with authority in the following matter

“The ASC’s mission is to ensure that real estate appraisers, who perform appraisals in real estate transactions that could expose the United States government to financial loss, are sufficiently trained and tested to assure competency and independent judgment according to uniform high professional standards and ethics.” From the ASC website.

The concern of this petition has to do with our “independent judgment” in performing real estate appraisals. We, the undersigned, represent a large number of licensed and certified real estate appraisers in the United States, who seek your assistance in solving a problem facing us on a daily basis. Lenders (meaning any and all of the following: banks, savings and loans, mortgage brokers, credit unions and loan officers in general; not to mention real estate agents) have individuals within their ranks, who, as a normal course of business, apply pressure on appraisers to hit or exceed a predetermined value.

This pressure comes in many forms and includes the following:

– the withholding of business if we refuse to inflate values,
– the withholding of business if we refuse to guarantee a predetermined value,
– the withholding of business if we refuse to ignore deficiencies in the property,
– refusing to pay for an appraisal that does not give them what they want,
– black listing honest appraisers in order to use “rubber stamp” appraisers, etc.

We request that action be taken to hold the lenders responsible for this type of violation and provide for a penalty on any person or business who engages in the practice of pressuring appraisers to do dishonest appraisals that do not provide for independent judgment. We believe that this practice has adverse effects on our local and national economies and that the potential for great financial loss exists. We also believe that many individuals have been adversely affected by the purchase of homes which have been over-valued.

We thank you for your cooperation and assistance.

This petition is now closed for further signing. 11,000 signatures should be evidence enough that a problem exists and needs to be addressed.

http://appraiserspetition.com/