New Housing Bill/FHA Loans

[Doug Wegener]

Furthermore

In my opinion, this is an example of a poorly written law. What does

“Certified by a nationally recognized professional appraisal organization” mean?

I think eventually HUD will have to issue a interpretive regulaton which fleshs this out and interprets what it means. Until then nobody will know what it means, probably including Brad Pack

Very muddy.

Is a IFA designation sufficient, or would it require a IFAS designation, neither of which uses the term certified. Does certified mean designated?

 

[Don Clark]

To answer a couple of questions in this thread: Some, but not all, professional appraisal organizations certify their appraisers though an on-going certification program. Generally these requirements are somewhat more stringent than what the state requires. I know this is true with the Appraisal Institute and also the American Society of Appraisers, of which I am a member, but not sure about other organizations.

I have a question for one of you regarding the FHA 2008 Reform Act. Has this gone into effect yet, or will it happen later this year? My wife - who is NOT certified by California - just was placed on the FHA roster. She is a licensed appraiser; will take the certification exam sometime before November.

By the way - we just had a 5.8 earthquake here in Southern California that really shook us up. Phones went dead - land line AND cell phone. All that worked was our MagicJack phone, which goes thru the computer....!

Jerry Lieb, ASA

Jerry,

First, I am glad you and your family are OK. I have family near, in laws as well as my sister in Aroyo Grande.

I wish I had answers to those posed here by Doug and you and others. All I have is what the bill says and what I have seen from the IA and NAIFA.

Until FHA comes out with some clarification in a Mortgagee Letter we will likely just keep guessing.

 

[Jo Ann Meyer Stratton]

As a designated member of both the NAIFA and the AI I am required to have the following statements in every appraisal report that I complete. NAIFA has been mandatory since 1961, AI became mandatory over ten years ago.

The National Association of Independent Fee Appraisers has a mandatory program of continuing education for designated members. Those who meet the standards of this program are considered to have been certified. I am certified under this program through December 31, 2009.
Jo Ann Meyer Stratton, IFA

As of the date of this report, I, Jo Ann Meyer Stratton, SRA, have completed the requirements under the continuing education program of the Appraisal Institute.

I certify that the use of this report is subject to the requirements of the National Association of Independent Fee Appraisers and the Appraisal Institute relating to review by its duly authorized representative.

In addition, I certify that to the best of my knowledge and belief, the reported analysis, opinions and conclusions were developed, and this report was prepared in conformity with the requirements of the Code of Professional Ethics and the Standards of Professional Appraisal Practice of the National Association of Independent Fee Appraisers and the Appraisal Institute.

 

[Michael Hinnant]

now that Bush has signed the bill does the part about FHA only using certified appraisers start now or later this fall?

 

[Greg Bell]

Never...So says FHA HOC....

 

[Doug Wegener]

Certified for FHA

Never...So says FHA HOC....

Can you expand a little about this Greg

 

[ZZGAMAZZ]

Everybody should be griping about the lack of "competency" of those who write muddled public policy. If thousands of appraisers immediately question the meaning of the verbiage, wouldn't the individuals who wrote the policy have anticipated the confusion that would follow?

 

[Tom McClure]

I agree, those writting the law should care more about the actual wording of the law.

However,

‘‘(A) be certified— 16
‘‘(i) by the State in which the prop- 17
erty to be appraised is located; or 18
‘‘(ii) by a nationally recognized profes- 19
sional appraisal organization;

I don't think being certified "by a nationally recognized professional appraisal organization" changes much since one must already be "state certified" as just one of many requirements for a designation. At least for designation with AI, ASA, and NAIFA.

Tom McClure, Ohio

 

[timd354]

I agree, those writting the law should care more about the actual wording of the law.

However,

‘‘(A) be certified— 16
‘‘(i) by the State in which the prop- 17
erty to be appraised is located; or 18
‘‘(ii) by a nationally recognized profes- 19
sional appraisal organization;

I don't think being certified "by a nationally recognized professional appraisal organization" changes much since one must already be "state certified" as just one of many requirements for a designation. At least for designation with AI, ASA, and NAIFA.

Tom McClure, Ohio

Yes, but the National Association of Real Estate Appraisers (NAREA) has a "Certified Real Estate Appraiser" (CREA) designation that only requires the designated memer to be a "State Residential Licensed Appraiser adhering to USPAP" or a "State Certified Residential or General Appraiser adhering to USPAP...it iwll be interesting to see if this qualifies under the statute.....seeing how the statute does not specify what constitutes a "Nationally recognized professional appraisers organization" and the NAREA claims 2,000 plus members with members in all 50 states, DC, and several US territories, it would seem that the NAREA meets the statuatory definition.

 

[TJSum]

Everybody should be griping about the lack of "competency" of those who write muddled public policy. If thousands of appraisers immediately question the meaning of the verbiage, wouldn't the individuals who wrote the policy have anticipated the confusion that would follow?

Most legislation is written by congressional staffers and/or lobbyists. The actual Congressmen rarely read it, just the highlighted parts they are most interested in.

The $64,000 question, did the person writing this know the difference between State Licensing and Certification Levels? And if they did, what Lobbyist wrote this and for what purpose?

P.S. Let us not forget most politicans are also lawyers, legislation is written in "legalese" with many gray areas on purpose, so that thousands of lawyers can make excelllent livings "arguing" what it all means.