TAF Responds to HVCC

[xmtpedprl]

More praise for USPAP. And that's how I feel, too.

Fine these guys, hit 'em where it hurts, progressively, and like Pavlov's Dog they'll get it. Or go extinct. All the chatter between the alphabet soups is for the birds.

Dave...

 

[Frederick]

More praise for USPAP. And that's how I feel, too.

Fine these guys, hit 'em where it hurts, progressively, and like Pavlov's Dog they'll get it. Or go extinct. All the chatter between the alphabet soups is for the birds.

Dave...

Dave, I think its often too hard to prove for that to be a viable solution. Pressure comes in so many different ways and it is rarely easily documented.

The originator needs to be held legally and financially responsible for the all aspects of the loan package he submits. The originator should be required to have a bond or E & O to cover that liability. When he carries that liability and his livelihood is dependent on a solid and well documented loan package then it will be in his best interest to get a quality appraisal, have real and properly verified employment and asset numbers etc.

E & O and bonding companies will do their due diligence on the broker and those with checkered pasts will not be able to purchase coverage. There is no need for any more bureaucracy.

That will solve "fast and cheap" and all other problems currently faced by the industry.

 

[JonGalt]

All that has to be done is begin to fine them, I've been saying it for years, and I can't for the life of me figure out why no one will implement such a program of progressive fines per attempt leading up to loss of brokerage (or other) license.

They won't do it because the majority of brokerages would go out of business if they were unable to use fraudulent appraisals inflating values.

Sure, you may think I'm just being negative but I've been looking for new clients for months and have not yet met a mortgage broker that did not demand comps and imply that numbers be met prior to ordering an appraisal. Want work? Play ball.

HVCC will never be implemented.

 

[Workbox]

Get the appraisal first, then do what you have to do after that. Very simple. But they want get them on the hook first, then control the rest.

 

[xmtpedprl]

Frederick,

No sir, not hard to prove at all, I politely disagree. In fact, abundantly easy to prove. I get things each and every day that are so offensive that they should go to great lengths in arousing the attention of those who have authority.

And Jon, you're not negative, just honest.

Dave...

 

[George Hatch]

I'm as big a supporter of The Appraisal Foundation as there is, but there are a couple aspects about this letter that make me a little uncomfortable.

On their website under the "Our Mission" tab, The Appraisal Foundation has the following:

The Appraisal Foundation, a not-for-profit educational organization dedicated to the advancement of professional valuation, was established by the appraisal profession in the United States in 1987. Since its inception, the Foundation has worked to foster professionalism in appraising by:

• establishing, improving, and promoting the Uniform Standards of Professional Appraisal Practice (USPAP);
• establishing educational and experience qualification criteria for the licensing, certification and recertification of appraisers;
• disseminating information on USPAP and the Appraiser Qualification Criteria to the appraisal profession, state and federal government agencies, users of appraisal services, related industries and industry groups, and the general public and;
• sponsoring appropriate activities relating to standards, qualifications and issues of importance to appraisers and users of appraisal services.

Anything that doesn't fit into the above activities strikes me as possibly being an example of mission creep. Obviously activities pertaining to establishing and promulgating appraisal standards and appraiser qualifications are part of TAFs mission.

I don't necessarily disagree with any of the suggestions or the apparent reasoning that goes with them, but it would make me uncomfortable if TAF made comments that fall outside the scope of its purview. Had they asked me, I would have counseled against making comments about the state boards, getting involved with banking regulations, and the like. No matter what happens or how these matters are decided it would position TAF in the middle of conflicts that fall outside its stated mission. As I see it, that is a no-win proposition for them.

I fear that critics of The Appraisal Foundation will sieze upon such comments as support for their arguments that TAF meddles in activities in which it is not charged. I can particularly see how a few of these state boards will cite these comments in their states rights arguments the next time one of them suggests (again) sunsetting the ASC and the AQB and turning USPAP into a suggestion or wish list.

Maybe I'm being paranoid again, but a couple parts of this letter make me nervous for TAFs interests.

 

[xmtpedprl]

George,

Even if such a thing were ever to *become* "perfect," even if it were ever to meet with your complete satisfaction (which would actually mean something to me), even if the whole world were to stand up and salute it, so what?

Wasn't FIRREA supposed to solve all the world's problems, never again leading us into financial doom and gloom?

Seems to me that if no gets punished that a bunch of well worded intentions results in a force equal to the paper upon which its written, maybe even wet paper.

Fine them, hit them hard, put a few down and watch the others take life a little more seriously. That's all that's needed. Sensibly applied fear works.

Dave...

 

[Fred]

Anything that doesn't fit into the above activities strikes me as possibly being an example of mission creep.

Isn't "independence" a USPAP issue and therefore the governance of independence a Foundation concern?
"Given the criticality of appraiser independence as it relates to USPAP, The Appraisal Foundation strongly supports any measures designed to bolster appraiser independence."
Also, isn't there the possibility that some regulatory effort might confound the goals of USPAP?

I fear that critics of The Appraisal Foundation will sieze upon such comments as support

The probably will, but they wouldn't they also sieze upon silence? BTW, am I not a "critic" of the Foundation?

 

[moh malekpour]

I am curious to know who are sponsoring the TAF. It says:

It is important to note that The Appraisal Foundation is an educational organization and not a trade association; in addition, over 110 organizations with an interest in the valuation profession are affiliated with us. These entities include professional appraiser associations, governmental agencies, major financial institutions, for-profit and not-for-profit companies, appraisal education providers, and others (including Fannie Mae and Freddie Mac).

Are those 110 organizations sponsoring the TAF?

There are only few professional appraiser associations who have a good reason to sponsor the TAF because at least they can claim that the want to promote the profession although I don’t know who is sponsoring them. But who are major financial institutions and others who are sponsoring the TAF and what do they expect to get back from the TAF? Could some of them be Countrywide, WAMU or some large nefarious national AMCs?
We know that there is no free lunch out there. Those who sponsor the TAF, they want and sometimes demand a subtle favor for their sponsorship.
Does anyone have a list of those 110 organizations that are affiliated with TAF and know what do they want from TAF in return?

 

[George Hatch]

Even if such a thing were ever to *become* "perfect," even if it were ever to meet with your complete satisfaction (which would actually mean something to me), even if the whole world were to stand up and salute it, so what?

Wasn't FIRREA supposed to solve all the world's problems, never again leading us into financial doom and gloom?

Seems to me that if no gets punished that a bunch of well worded intentions results in a force equal to the paper upon which its written, maybe even wet paper.

Fine them, hit them hard, put a few down and watch the others take life a little more seriously. That's all that's needed. Sensibly applied fear works.

It may appear that my previous comments were an endorsement for the HVCC, but that's not how I intended them. I was referring to the role of The Appraisal Foundation - a role that they have defined for themselves.

I have no problems with ramping up enforcement or with anyone advocating that. As I said before, I don't disagree with the comments in the letter or the reasoning that goes with them. I'm just a little concerned about some of the areas being commented on and how that might backfire on TAF, even if they are on target.