"Not all ..., - Not all, ...,..." This shows the weakness of the legalistic/regulatory point of view in dealing with problems. It really explains why nothing real has been accomplished in the past 20 years with regard to overvaluation by appraisers. .... It ignores issues of cause and effect, probability/risk, feedback and other systems theoretic factors.
Congress has just passed new laws and regulations. But the "system" is still intact. Will somebody PLEASE fix the system?
Bert Craytor, SRA
Ms. Craytor,
Thank you! ... I said it too. Differently, but I said it. I said these last questions and answers simply were not needed by anyone. I know, you know, all our boards know, that appraisers cannot send out misleading appraisal reports... Duh! .... I know, you know, everybody knows, that appraisers should not accept assignments with contingent results... Duh! .. ALL of this has been in every USPAP class for years now.
What all
appraisers across this country
needed was
an authority to determine if web portals and conversion programs, each one specifically, was doing something that resulted in a
misleading appraisal report if that web portal or conversion software was
used by any appraiser. What we DID NOT need was to be told that all of us, individually, are responsible for figuring out high tech stuff, that may have secrets and programing not being disclosed to us, may or may not result in misleading appraisal reports! The responsibility for this should have been dumped right back on the businesses pressuring appraisers to use those portals, and conversion programs, by requiring
those businesses to prove no prostitution of appraisers reports was going on and that this be approved by all state appraisal boards
for publication of that approval before any appraiser could comply and use any of them!
Next, this stuff of just telling us, yet again, no contingencies can be at play, in a following second assignment, if we do this so-called "Comp Search" stuff is not a solution.. Like the above, it is just dumping another "Duh" on all the appraisers without bothering to tell any of them exactly how they are supposed to do that. Setting up all appraisers for a fall if our dear authorities should decide that our individual solutions was not a solution in their opinion. So our guiding agencies continue with NOT providing our industry approved solutions. They do however reserve the rights to penalize all of us if we try to solve it for ourselves, like they basically told us we have to do, but they don't like our 10,000 different solutions we came up with due to no real answers from those agencies that actually solve the problems.
It's why I said the mission of these agencies have to be changed. Dumping everything back on a country of appraisers to solve is not working. It has not worked, it is not going to work. Just saying
"We will whack you if you don't do it right, but we will not determine what right is, only what wrong was when we whack you" is the wrong mission.
Webbed.
