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Virgina REAB and Portal Petition

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Some clients who accept PDFs will not accept digitally locked PDFs. If they don't, then the appraiser still has to make the decision whether or not to decline the assignment for that reason (if they know it up front). And the client is free to discontinue use of that appraiser for that reason.

Yes, but a digital signature can be applied to a PDF that has not been "locked." The report could be changed, but the digital certificate would alert a reader to that fact.

The sample I posted is not locked. Change it and see what happens. Forward it somewhere and see if the signature is intact.

Since the certficate on that sample says you have to contact me for verification, verification can be provided for as long as I wish to keep a copy. If one uses server verification, the time period is based on the service one buys.

Clients cannot, by law, refuse a report because it has a digital signature.

Gotta run.
 
Everyone:
Digital signatures will not fix anything, period. If we can put it in, they can take it out. Fraud and changing reports will remain no matter what we do. We all have common sense; we all already understand these things.

Technology affords us convenience and better profit margins than paper reporting ever did. We will always use it from now until something better comes along. The problem we have and I mean real problem is not vaulting in a national database; we can all collectively protect and keep our own copies in original format for cheap. The problem is the need for appraisers to be able to define and implement our own scope of work with every assignment that we do. FNC and the rest of the conversion companies out there force appraisers to play by rules that really alter what appraisers would normally do. We have everything we need right now. Simply deliver it in a PDF copy, to the client and its management company. If the management company needs to run QC/review functions on XML data, then they have the tools to take the PDF and convert it for themselves. It really is that simple. They want us all to pay them for the work, allow them to convert it into strippable fields, and do not want to invest in technology that will leave us all to our own devices to legally do our jobs. Instead, they force the little person to do the dirty work.


Woody Fincham
Virginia Beach
 
USPAP Issues:

As the words exist today in USPAP, I see no basis for finding that use of AIReady violates USPAP. When the ASB issues opinions, they must do so based on the words that actually exist in USPAP (what it actually says, not what they wish is said). The ASB stated long ago that it was not necessary to have a paper copy, and they did so because of the words in USPAP, not because of how anyone "felt" about any particular software.


Danny,

I’m reading the 2008/09 version of USPAP wherein the Record Keeping portion of the Ethics Rule (lines 280 thru 294) essentially states that the appraiser must prepare a workfile, have custody of that workfile or make arrangements with the party having custody for access to the workfile.

We historically believed that the modified appraisals showing up in the hands of clients were changed by some party other than the appraiser (no USPAP violation). Now we discover that’s not so. The appraiser’s software is actually modifying the report and forwarding it, thus making the modified appraisal the true report. That’s not a USPAP violation either as USPAP is not “format” specific.

Evidently the appraiser is unable to retrieve a copy of this true appraisal once the report has been modified. As a result, the appraiser is unable to produce a complete workfile upon demand. That is a USPAP violation.

Consequently, I can only conclude that an appraiser using the AIReady delivery system, or any similarly flawed system, is in violation of USPAP. That’s my view as a long time appraiser and as a state regulator. I’m sticking with it until someone explains the flaw in my logic (without a lot of soft shoe, smoke and mirrors.)

Oregon Doug
 
Doug,

Line 284 of the 08/09 USPAP states: "true copies of any written reports, documented on any type of media;"

The converted file, which is delivered to the client or the client's agent, remains on the appraiser's hard drive as, in the case of AIReady, an ENV file. If the requirement placed upon the appraiser is to produce their workfile upon demand, if the appraiser copies that ENV file on to a CD and presents that CD to the Board, is not USPAP satisfied?
 
OK, we may see what goes out with the conversion, but what do they (lenders) really see/get when they pop it up on their screens? How are they saving it in case we do need to get the converted copy? When AHM went BK, I received many phone calls to send them the appraisals, because they could not find them. ??
 
Danny,

I’m reading the 2008/09 version of USPAP wherein the Record Keeping portion of the Ethics Rule (lines 280 thru 294) essentially states that the appraiser must prepare a workfile, have custody of that workfile or make arrangements with the party having custody for access to the workfile.

We historically believed that the modified appraisals showing up in the hands of clients were changed by some party other than the appraiser (no USPAP violation). Now we discover that’s not so. The appraiser’s software is actually modifying the report and forwarding it, thus making the modified appraisal the true report. That’s not a USPAP violation either as USPAP is not “format” specific.

Evidently the appraiser is unable to retrieve a copy of this true appraisal once the report has been modified. As a result, the appraiser is unable to produce a complete workfile upon demand. That is a USPAP violation.

Consequently, I can only conclude that an appraiser using the AIReady delivery system, or any similarly flawed system, is in violation of USPAP. That’s my view as a long time appraiser and as a state regulator. I’m sticking with it until someone explains the flaw in my logic (without a lot of soft shoe, smoke and mirrors.)

Oregon Doug

Doug:

It's funny, you see things as I do. However as a regulator, I hope you see the problems that allowing these guys (FNC et al) to continue to do work like this, many naive appraisers are doing non-compliant work. It's the Board's job in every state to challenge these things for not just appraisers but for the public at large.

I would ask out of respect for my industry, and those that came before me, why Mr. Wiley seems to always hold AppraisalPort in such good light? I have talked to many, many residential appraisers and of those that are in the know, all seem to have a negative feelings toward the RDB that has become AP. They also have serious problems with how the AI turned their backs on us. Is there a connection between all of this? I hate conspiracy theory, but it does have it's place. I just wish it was not here and now. I am thankful we have some real friends in the industry who are willing to fight the good fight

Woody Fincham
Virginia Beach
 
Woody, considering your affiliation with alaMode, would you describe your opinions on this subject as unbiased?
 
Doug,

Line 284 of the 08/09 USPAP states: "true copies of any written reports, documented on any type of media;"

The converted file, which is delivered to the client or the client's agent, remains on the appraiser's hard drive as, in the case of AIReady, an ENV file. If the requirement placed upon the appraiser is to produce their work file upon demand, if the appraiser copies that ENV file on to a CD and presents that CD to the Board, is not USPAP satisfied?

How is the Board supposed to read it? .ENV files are propriatary files. Even a la mode can not vie them, and they submit code for conversion. You would be held non-compliant as you as the preparer can not even red it.

Woody Fincham
Virginia Beach
 
Reread line 284 of 08/09 USPAP and show me where it states that the appraiser is responsible for the Board's inability to read a report "documented on any type of media."

The Board's lack of a program adequate to read the ENV file is not a USPAP violation.
 
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