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Public Trust or Business Practice?
February 21st, 2016 7:01 PM
Public Trust or Business Practice? 

VaCAP wants your opinion!  

Is the practice of email blasting appraisal assignments an issue of Public Trust or is it a Business Practice? Please share your thoughts. 

Posted in:General and tagged: AMC's
Posted by Virginia Coalition of Appraiser Professionals on February 21st, 2016 7:01 PMPost a Comment

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The email blasts and the text messaging systems are most definitely a public trust issue. They do not allow an appraiser ample time to research the property to determine if they are qualified to perform the assignment. The assignments advertised through these systems are usually below customary and reasonable fees and often are sent outside of normal business hours. Often there is no opportunity to counter the offer, a fee or turn time. These systems are not in compliance with the Dodd Frank Legislation and are harmful, not only to the public, but to communities, neighborhoods and the appraisal profession.

Posted by MIke on February 21st, 2016 7:31 PM
Email blast orders are clearly an issue of public trust. Specifically a violation of sound public trust procedures. Orders offered to multiple bidders at one time necessarily result in orders being assigned based upon speed of response and cost bid rather than appraiser competency for the specific assignment. It ALSO eliminates the ability of the licensed appraiser to participate at all. AMCs operate on the assumption that if only certified appraisers are hired, that 'of course they are competent' to "do anything", regardless whether it’s the area of expertise or not. It amounts to restraint of trade, and may well violate Federal Commerce laws! I have over thirty years experience in highly complex assignments. I'm a former Treasury Department Sr. Appraiser. It takes me close to an hour to confirm the (apparent) 'ownership interest ' to be appraised. Without knowing that, how can one determine their competency? The AMC's take the approach that competency is a burden for each of us to determine for ourselves. They operate as if that burden can rightfully be delegated to the appraiser. The ASC; TAF, and regulators however do NOT agree with that. It is the LENDERS responsibility to assure competency of the appraisers they give work to. ASC sees ZERO room or daylight between the lender and their agent AMC. There is no regulatory 'cover' for the lender failing to comply with THEIR obligations to assure appraiser competency. The current email blast practice ASSUMES competency with no effort to determine actual competency for the specific assignment being offered. It also undermines the requirement to pay reasonable and customary fees as required under Dodd Frank. A fee offered, or bid, without confirmation of the assignments complexity FIRST cannot be considered either reasonable or customary. The "Public Trust" is based upon all parties operating ethically and competently to carry out the requirements of FIRREA; Dodd Frank, USPAP (where applicable) and individual State Regulatory requirements beyond these. An appraiser is held responsible for serial minor errors that by themselves are not significant but that when compiled cumulatively, negatively affect the quality and credibility of the work performed. So too must FNMA, Lenders, and their agent AMCS be held accountable. The entire process designed to minimize regulated GSE and lender/AMCs costs has undermined both the public trust; and the professional appraisers trust in the entire appraisal process. The repetitious erosion of common sense good business practices and legislative compliance requirements has diminished trust in all residential one to four unit appraisals to the point that some consider them no better than AVMs or spurious "valuation" software that uses regression as the sole determinant of value. Clearly that dos not serve 'The Public Trust.' Respectfully submitted, on behalf of the American Guild of Appraisers (AGA), #44OPEIU/AFL-CIO and our over thirteen million consumer / taxpayer members; their families and retirees, as well as the Guild appraiser members. Michael F. Ford, SCREA, AGA, GAA, RAA, Realtor ® VP/Chairman National Appraiser Peer Review Committee American Guild of Appraisers (301) 220-4100 Guild Number (714) 366-9404 Ford's Number

Posted by ike Ford, AGA, GAA, RAA on February 21st, 2016 8:44 PM