The real point is that we have a foreign national on OUR regulatory agency practices board. Give me a call sometime and I’ll go over the history of my concerns and it goes back to the AICPA (business valuator CPAs) take-over of appraisal regulations in America. Not something I prefer to put into print.

Hi RA, Too funny when we start agreeing! Most on the blog would be as surprised as we are..

Fact is I agree with you so strongly on this I am forwarding your email to the VaCAP contact’s I have. They are currently considering a recommendation to the State Board there to adopt the VA schedule as the “presumptive minimum C&R fee”. I’ve offered a view indicating even that fee is far too low—though better than nothing.

Interesting aside to this. I thought we covered everything in the draft C&R proposal put forward by the AGA but we didn’t. Since I’ve been working with members facing state investigations arising from complaints by disgruntled home owners; agents, and even RELS/Wells Fargo covering up for their ‘habit’ of appraisal shopping until they get the result they want, I think we ALL need to start including a contingency fund for legal defense in our operating budgets.

This is above and beyond E&O. Hiring an attorney merely to represent one at the state Administrative Hearings are over $5,000 alone!. For an appraiser that starts off with an attorney on receipt of a complaint, it is even higher.

Since Dodd-Frank, lenders ordering second appraisals ‘due to [alleged] deficiencies’ in the original appraisal (a requirement in order to ‘shop’) also have a requirement to turn the appraiser in to their state Boards or CFPB. Some are apparently adopting this as a business model. I am seeing it more and more each month.

(1) They violate DF by value shopping; (2) get a phony desk reviewer to ‘find fault’ (3) Find a trained seal-appraiser willing to use their suggested comps and value (4) Over appraise the property and fund the loan (5) THEN to cover up and establish a paper trail ‘of compliance’, they turn the original appraiser in!

It’s not enough that ‘they’ commit loan fraud. They get extra nasty and destroy the appraiser’s professional reputation and life in the process!

Even when the complaint is obviously spurious on the surface, the appraiser either spends a LOT of money getting legal representation, or is at the whim and subjective biases of individual state investigators. I’m seeing increasingly excessive “punitive bent investigations” rather than objective PEER REVIEWS. Over charging for minor technical oversights, etc. are being used as a cudgel to coerce appraisers into signing ‘consent’ agreements.

Even a single complaint say every ten years is $500 to $1,000 extra a year that has to be set aside. A prolific firm; or one with numerous trainees could face ten times these amounts without doing anything wrong!

Keep posting my friend. I’d personally prefer to see a solution-driven direction, but you DO make others think…and that’s a big start.

OMG!  Mike Ford & I agree on a point…a very significant point.

Appraisal fees today should be in the $800 range for a basic appraisal.  Keep in mind I said SHOULD BE.  This is taking into account a 30% increase in expenses since 2009, a 1000+% increase in liability, and a 150% increase in workload per appraisal.

Will you see $800 for a basic appraisal?  Not a chance but $450 to $500 is far too low considering the above data.

Virginia must not have rent control; varied leases or special state rules governing disabled tenants rights-because the fees being cited certainly do not allow for their analysis.

I respectfully submit the AGA C&R fee proposal (even the lower one for Virginia’s lower COLA) makes much more sense as the presumptive minimum. If for no other reason than IF they do not get what they ask for, where will the fee finally fall? 10% less? 20%? 50%? (Flagstar recently was reported to have cited a $200-$250 range as being “reasonable” in the C&R litigation down there.

Ask for MORE, not less! IF you cannot prevail with the Federal OPM fee based equivalents THEN you can always “settle for” something close to the VA fees. Read the full proposal for yourself at:

http://mfford.com/html/c___r_fees.htm or http://www.appraisersguild.org/ (click on News Feed section)

The author IS right about communicating though. I spoke with the Executive Director of the Appraisal Subcommittee last Friday. He made a point of noting how few Dodd Frank and other complaints are being forwarded by appraisers. Members of TAF/APB reiterated the limited communications from independent appraisers and their STRONG DESIRE to see much more communication from ‘us’ collectively. More on this later.

Action in the world of real estate appraisal leaders = More Meetings, More Letters, More Polls.

Picture Clark Kent (Nerd Hero) without the ability to transform himself into Superman and you have a clear vision of the average national appraiser leader.

*Able to write a mountain of complaints in single minute.
*Willing to bill it’s members millions for annual dues without lifting a finger for services rendered.
*Able to dash off a new new new version of USCRAP with the flash of a pen.

I would follow Thomas “Bubba” Paine as a leader any day over the current Appraisal Institute, USCRAP, Appraisal Foundation leaders. He appears to be one of the few who realizes this “profession” is rotting from the inside out…due to what? Due to a lack of REAL ACTION on the part of appraisers.

NEED ACTION!

the bleeding continues . . . . .