Tagged: AGA

Appraisers Should Never Do Evaluations - Appraisers Blogs 15

Appraisers Should Never Do Evaluations

…users of evaluations knew & accepted that if they obtained evaluations in lieu of real appraisals that they were getting meaningless value opinions by unqualified personnel… TALCB will be considering the Board’s position regarding appraisers performing evaluations in compliance with USPAP at the next Board meeting on August 23, 2019 Dear Texas Appraisers Licensing & Certification Board Members: The short and sweet version is that appraisers should never, repeat never do ‘evaluations’. The term itself should never be uttered as if it refers to any legitimate appraisal product that meets the USPAP requirements of a real estate appraisal. When FIRREA...

Bifurcated Appraisal Fans Can Claim SOW Till They're Blue in the Face 50

Hybrids vs USPAP Scope of Work Rule

Supporters of the bifurcated appraisal can claim scope of work till they are blue in the face… Appraisal Buzz published an article written by Joshua Walit on July 31, 2019 titled Nothing New Under the Sun: The Varied Face of Appraisal. The article brings up some good points, however; it does not take into account the reality of the market and the control of the lenders and appraisal management companies in the process. The mere fact that the appraiser does not have control over the person completing the inspection and in most cases, no way to even know who is providing the...

Review Appraiser Flawed Review... Phony Complaint Against Appraiser 14

Phony Complaint Against Appraiser

…a laundry list of ‘pile on’ purported USPAP “violations” were fabricated deriving for the above oversights ‘confirmed’ by the out of area review appraiser… In fighting or appealing a false complaint filed against you as an appraiser, truth, factual evidence and professional competency is no longer enough! More important than all these things, is conformity to the detailed technical rules of a state’s administrative law procedures. In short, in many if not most cases, appraisers MUST HIRE AN ATTORNEY to represent them before any administrative board. Anything less, is playing with fire and your professional career. Worse, E&O won’t cover...

Complain About a Complaint Filed - Who Can Complain About Appraisals 72

Who Can Complain About Appraisals?

Time to get on my soapbox and complain about a complaint filed against me (not a charge, but merely a complaint). I did an appraisal of a multi-family property near my office. The property owner/borrower called me to complain about the appraisal since it came in far less than she thought it should (not unusual). Clearly, I could not answer her questions since she was not the client. This upset her greatly, so she filed a complaint with the State. The complaint had no basis in substance. In fact, the complaint was that my appraisal was too low. Since neither...

Hybrids, Invitation to Fraud - The New Subprime Fiasco of This Decade 6

Hybrid Appraisals, Invitation to Fraud

Until FNMA released their version of a test format for hybrids (1004P) there was not one hybrid form appraisal process and online form reporting system found that was not egregiously misleading in the entire country. Not one. Not Clarocity’s, nor Clear Capital’s or Mueller Inc. A “typical hybrid” sample follows. https://appraisersblogs.com/clearval-value-hybrid-appraisal Not those crafted in Hyderabad, Pakistan for $8 Billion for just one year’s Wall Street Investments (as published by Cezary Podkul Wall Street Journal) where the preparers claimed to be able to produce 360+ per day by illegally using broker login credentials from state-licensed brokers in America. The entire...

Special Interests Killing Consumer Property Value Protection 13

Killing Consumer Property Value Protection

Before the ink was dry on FIRREA 1989, special interests were snipping away at it. Originally proposed field review requirements in FIRREA drafts for 1 in 10 appraisals would have made the Great Recession (TARP) impossible. Now those same interests are stripping away at the last vestiges of consumer and taxpayer property value protection. The formal appraisal. The MINIMUM level of protection that should be insisted upon. Dear Ms Kahng: My name is Mike Ford. I am Vice President – Special Projects; & Chairman of the American Guild of Appraisers National Appraiser Peer Review Committee; AGA#44, OPEIU, AFL-CIO. I am...

Will the Cost Approach be Required in the Redesigned UAD Forms? 50

Returning to Requiring the Cost Approach

…the Cost Approach is the most INACCURATE of the three current ‘Approaches’ we use… Appraisers, for the past few weeks, emails have been sent by a third party asking appraisers to complete a survey about the appraisal process and the current forms. I did so; you should also. But I wanted to expand on one aspect of the survey. Two separate questions, on different survey pages, related to the Cost Approach (CA). These questions wanted appraisers to state their opinion about 1) if the forms provide adequate detail to develop a CA, and 2) if it is or is not...

Protecting Appraisers Against Frivolous & Retaliatory 3rd Party Lawsuits 6

Frivolous & Retaliatory 3rd Party Lawsuits

Appraisers are routinely coerced & intimidated by third parties to violate their independence and integrity… Honorable Committee Members: We are writing to add our voice to that of the Massachusetts Board of Real Estate Appraisers (MBREA is a State Coalition of professional real estate appraisers) in support of each of the above bills. The American Guild of Appraisers is a Guild within the Office Professional Employees International Union (OPEIU) of the AFL-CIO, representing the appraisal and real estate related financial consumer / taxpayer interests of over twelve and a half million AFL-CIO Family Union & Guild Members; their families, retirees...

Unintended Users Phony Low Value Claims Against Innocent Appraisers 6

Phony Low-Value Complaints

ALL unintended users are specifically excluded from any right of reliance on this appraisal report… Recently, Mr. Steve Kahane, Board Member of the Association of Texas Appraisers (ATA) wrote a great article in WorkingRE. It included several suggestions for Texas to deal with it’s excessive number (70%-75%) of unfounded complaints against appraisers. An American Guild of Appraisers member in New Jersey who has twice faced this exact kind of complaint abuse reminded me of the article and concurred with its suggestions for his state. Fortunately for our member, New Jersey is not one of those relatively few ‘charge and win...

North Dakota Bankers Seeking to Eliminate Consumer Protection Benefits 5

ND Banks Seeking to Kill Consumer Protection

…North Dakota bankers seeking to eliminate consumer protection benefits associated with appraisals… The real issue of concern to all appraisers is the attempted con job and subtle coercion by officials and State Senators in North Dakota over the ASC. In their letter to ASC regarding their appraisal waiver request, they cite only 170 ‘in area’ appraisers while excluding a hundred so-called out of the area (multiple state licenses). While North Dakota is about the 19th largest state in land area, it is the fourth lowest in overall population. The 2018 population was only 760,077! That makes it among the lowest...

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