TAF Charging for Misleading Classes

TAF Is Making Appraisers Pay To Be Misleading And Exposed To Legal Jeopardy. From the organization that brought you the bat-shit crazy letter and the chickenshit letter, they are charging for classes that are misleading.

ASC just sent a letter to state appraiser regulatory officials pointing out that the USPAP update course is factually inaccurate and puts appraisers in legal jeopardy if they follow it.

Letter From Jim Park, Director ASC to State Appraiser Regulatory Officials: 2022-2023 7-Hour National USPAP Update Course

The letter references findings and recommendations found in the already presented report 6 months ago: Identifying Bias and Barriers, Promoting Equity: An Analysis of the USPAP Standards and Appraiser Qualifications Criteria

This is the meat & potatoes of the July 8, 2022 ASC letter:

The new fair housing module contained in the 7-hour continuing education course reflects welcome effort, but fails to provide accurate and effective guidance to appraisers. The module provides an inaccurate summary of fair housing law, while failing to include any content from the applicable statutes themselves (namely, the federal Fair Housing Act) or its implementing regulations. It also fails to provide specific guidance and examples of what is prohibited by law. This outcome is consistent with views expressed in interviews conducted with members of national appraisal organizations. They observed that The Appraisal Foundation has not produced accurate and effective guidance with respect to fair housing issues (and other topics of a legal nature, such as privacy laws).

ASC is essentially telling the 55 states and territories they don’t need to enforce this aspect of USPAP because the TAF course is inaccurate. In fact, the NFHA report that came out last January 2022 goes into specifics on why TAF’s effort is misleading. Yet TAF hasn’t pulled the USPAP class because it is their cash cow.

Why do we need a USPAP update class at all in this cycle? Key word here is “update” since we are in the third year of the two year renewal cycle “extended because of COVID” (lol), and we are still required to take the update class.

Let me summarize the situation for you:

  • There have been no changes to USPAP in more than two years yet they have no problem charging appraisers to take an “Update” class to maintain certification. This is the definition of both a money grab and busy work, both of which come out of the appraiser’s pocket and takes away from time they could be making a living.
  • The fair housing module to the class is factually inaccurate and can place an appraiser in legal jeopardy as a result.

Beyond that, TAF’s focus of the update class really is:

“How do I not get accused of bias?”

…rather than giving appraisers the tools they need to understand things like the difference between implicit and explicit bias.

Echoes of misleading

Does this situation sound familiar? It should. Remember when I called out TAF more than a year ago for their reckless use of the term “misleading,” because they doubled down by saying either “unintentional” or “intentional” misleading statements could place your license in jeopardy. They placed the appraiser on the hook in reference to the term “misleading” and are too lazy to take it out immediately until it is fixed or never put back in. How hard is that to do? How many minutes would it take to do their actual job on fixing the “misleading definition?” My wild guess would be 5-10 minutes.

As always, this addition to USPAP was done without legal review which is one of the core problems of the USPAP process. TAF has now brought in a law firm, but my goodness, this has been going on for more than three decades and the interpretation of “misleading” is still on the books?

For a small staff, this is an incredibly bloated institution.

Jonathan Miller
Image credit flickr - Gary Stevens
Jonathan Miller

Jonathan Miller

Jonathan Miller is President and CEO of Miller Samuel Inc., a real estate appraisal and consulting firm he co-founded in 1986. He is a state-certified real estate appraiser in New York and Connecticut, performing court testimony as an expert witness in various local, state and federal courts.

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9 Responses

  1. Avatar Pat Turner says:

    You know, this is getting to be a clown show!

    Why is it we are inundated with more and more and more to do but hurry the hell up and get this appraisal done in 24 hours or less.

    Just look at the AMCS that brag about their ridiculous turn times of less than 24 hours. Uh oh, they say nothing about appraisal quality nor will they assist the appraiser in the appraisers’ complaints.

    This is truly becoming a cluster screw!!

    • Avatar Mark Skapinetz says:

      Faster faster faster. The faster the AMCs get things in the better they look to THEIR clients the lenders who they have signed contracts with. The faster lenders do things the better they look.

      However we are in a day and age now that faster is supposedly better and that is coming from the likes of AMCS, companies like Regorra, Clear Capital, Class valuations and others that are only concerned with themselves and not the consumers that they get paid by. They are the ones that push this crap. They are the ones that think they can develop technology that can do this.

      What they fail to tell anyone is the truth. Say it 1000 times, post it on social media over and over and it must be true. Right?

      In the real estate appraisal profession we have so many laws and regulations to abide by. So many complex assignments, so much data to examine and look at. Yet everyone else out there just has to sit their asses in a seat, wait and collect their commissions. The appraiser is subjected to all sorts of scrutiny, having demands made to them, told basically that their fee is too high, and then has to wait 30-60 days to get paid for their services which is a fraction of the paycheck a loan officer, realtor or others make when they close the deal yet appraisers have to take on most of the liability.

      Most of these companies out there pushing the 24 hour turn time have absolutely 0 notion of what the appraiser actually does. They don’t care either. It’s a race to the bottom to pad their pockets with money and have their egos lifted that they know best. They aren’t concerned with the consumer or protecting the public trust. They just want to be able to tell everyone how amazing they are to gain more business.

      Everyone wants speed these days. Faster internet, faster deliveries, faster everything but we see this everyday in the appraisal profession. More and more appraisals being sent back due to errors and more contained within the reports. Why? Because appraisers are forced now to do things quicker and sacrifice quality.

      These aren’t my words. These are the words of another and something to consider. The words of W. Edwards Deming. (Look him up)
      The following is from an article I read about speed vs quality.

      “The more quickly a job is performed, the higher the chance of an error or mistake. Software updates are released too soon, full of bugs and glitches. New phones are rushed to market, often with serious defects such as combustive batteries. Haste is often the enemy of quality. That is why there are also sayings about the problem of rushing. Haste makes waste. And haste does not produce breakthrough ideas. Tham Khai Mend, Worldwide Chief Creative Officer at Ogilvy, one of the world’s leading advertising agencies, once said “Miners shift five tons of rocks to extract one ounce of gold. Just like you have to shift a ton of rubbish to get a good idea.” Detailed or creative work requires a great deal of thought, research, concentration, reflection and mulling over to produce the truly valuable nuggets. It is a process that cannot be rushed. And, work that requires precision and accuracy — such as surgery, architectural design, accounting, proofreading, and dispensing medicine – also cannot be rushed. In such work, quality is arguably more important than speed.

      DID YALL CATCH THAT… Well here is more…
      “With regard to quality and speed, he believed that employees shouldn’t be evaluated based on the quantity they produced, but rather on the quality, of their work. To evaluate on quantity alone would be to remove pride of workmanship. Ultimately, Deming believed that improving quality did affect productivity because it eliminated mistakes, customer complaints, the cost to repair or replace defective work, duplicate work and wasted materials.

      Pretty smart man in my opinion and who’s words I incorporate into my business.

      “Deming’s advice to business owners today would likely be that if the choice is between speed or quality, choose quality and reward experience because those will ultimately improve speed.”

      Catch that… REWARD EXPERIENCE!!! Oh wait I’m sorry that’s not the business model of AMCS because that would require paying more for the product and less they can take from the appraiser.

      The world has changed. Everyone wants faster but fails to see that quality will suffer. AMCs and more are greedy. They want to be bigger and stronger and the only way to achieve that is through speed. They all sacrifice quality for speed. They all take the opportunity to pander to the issues at large and claim they can be better than anyone else. It’s a sad world we live in.

      TAF, ASC, and all the others will do whatever it takes to make themselves look good to everyone out there yet they will not tell the truths of what they are doing. They won’t tell the truths of how they sacrifice quality over speed. They won’t tell the truths of how they will do whatever it takes to remain relevant. They won’t tell the truths of their financial gains. They won’t tell the truths to anyone period.

      The truth is this.. the public and the trust is being screwed over every day for financial gain and it’s not the appraisers who are doing it. It’s the people making the laws, regulations and more that are screwing you.

  2. Rvs Simon on Facebook Rvs Simon on Facebook says:

    USPAP is 20 minutes of information and 6 hours and 40 minutes of CRAP

  3. Avatar That Scott Guy says:

    It’s all about money.

    Well, that and control. I love the new USPAP ‘errors of commission and omission’ deal, giving the powers that be the ability to hang appraisers for ANYTHING.

    *State Boards clapping*

    UPSAP and the ASC/TAF have removed all doubt that they are all incompetent.

    • Lori Noble on Facebook Lori Noble on Facebook says:

      The weaponing of USPAP and ASC encouraging state agencies to violate Administrarive Procedures Act is an obscure way to hold each other accountable.

      Meanwhile, licensing and regulations go mostly unsupervised and it shows in current events.

  4. Avatar Hk says:

    Thank you for putting this article together! It accurately describes what is going on and what I have been thinking for a while now. Please continue to post, your views on this subject are very important.

  5. Cash Cow is quite accurate.

  6. Avatar Bryan says:

    Just read an article about the “beneficiaries” of USPAP. Irony!


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TAF Charging for Misleading Classes

by Jonathan Miller time to read: 3 min