Anyone Going To Valuation Expo ** Las Vegas In August ?

[chad hampton]

Independent absolutely means you don't work for the company that is required to engage in someone who is independent.

 

[meatsandbounds]

This is an interesting thread. Valuation Expo, work, vacation, a bit of both. To each his own, but I must wonder about looking forward to going there unless you work for a company that requires your presence. For those of you who don't have to go and are there just to learn more about the appraisal industry I've got to ask. When you do finally take a few minutes to relax poolside with an adult beverage, are you reading Henry Harrison while soaking up the rays?

It’s in the 100’s out here, so not really worth being poolside till after 5. But for myself, I found a great karaoke place that just opened a few months ago right on the strip yesterday , and the same company runs karaoke in the hotel I’m staying in during week days, so I’m set unless I’m doing dinner with other appraisers this week, haha

 

[chad hampton]

You better let the Big AMCs know because it's been 13 years and nobody's sent them a memo or come knocking at their door. : ) lmaoo

They all started off playing by the rules. It's only need about 3-5 years they started pushing for staff - after they behavied so poorly that they couldn't find apprasiers to work for them any longer. And after all that revaa money scared enough regulators off. If you've even seen who sits on state boards, you'll see they scare fairly easily.

Again, don't just assume everything going on is above board just because no one is stopping it. The rulebreakers and unethical actors always get their turn in the barrel eventually.

 

[meatsandbounds]

But there’s not any shows I care to see, so it’s mostly just people watching for me, haha

Maybe catching up on reading

 

[George Hatch]

Independent absolutely means you don't work for the company that is required to engage in someone who is independent.

The operative term in the law is "appraiser independence" and those requirements are spelled out in writing. These regs pertain specifically to the regulated lenders. Take note of the date, and take note of the fact that this section of the regulation has not been retired: it is still in force as of the date of the most recent amendment in 07/2025. The reasoning and application was all spelled out prior to licensing coming online, ansd it never referred to the idea that lenders can only use appraisals or reviews performed by fee appraisers. the "independence" being referred to was from the loan originators, not from the lenders themselves as you seem to think.

The subsection pertaining to the engagement of fee appraisers is noted in the 2nd section. Not by itself and in isolation to the section pertaining to staff appraisers.

 

[George Hatch]

Nor do I think you will find any prohibitions at the GSEs that prevent them from accepting appraisals performed by staff appraisers at either the lenders or the AMCs.

Like it or not, the business of performing mortgage lending appraisals has never belonged solely to the outside fee appraisers.

 

[chad hampton]

If you don’t see how AMC employing staff appraisers is a problem, then I don’t know what else I can say. It’s a fairly simple concept to understand.

AMCs aren’t lending institutions. I have no issue with lenders lending their own money doing whatever they want.

In fact, some AMCs don’t need to be registered in my state because they are subsidiaries of a lender. I think red sky is one. No issues with that, they are complying with the state law.

 

[George Hatch]

If you don’t see how AMC employing staff appraisers is a problem, then I don’t know what else I can say. It’s a fairly simple concept to understand.

AMCs aren’t lending institutions. I have no issue with lenders lending their own money doing whatever they want.

In fact, some AMCs don’t need to be registered in my state because they are subsidiaries of a lender. I think red sky is one. No issues with that, they are complying with the state law.

I completely understood your complaint the first dozen times you made it. It's a problem for your business interests. It isn't a problem for the lender's legitimate due diligence functions.

Go back to the original intent of cutting the MBs out of the loop for the FRTs in 1990 and the SFRs in 2008. Same reason - the loan salesmen have no legitimate business even touching any aspect of an appraisal assignment until after it has been completed. That's the inherent and incurable conflict of interest between loan production and due diligence.

When working to specs, neither the appraisal depts at the lenders nor the AMC are operating that way. There is no conflict of interest that would compel the govt to prohibit either of them from using employees to appraise properties - as long as they are isolated from the loan origination side of the business.

As of 2025 the use of "staff appraisers" it isn't prohibited. Maybe someday govt will take the additional step and outlaw staff appraisals, too; but that day is not near.

 

[Dublin ohio]

In fact, some AMCs don’t need to be registered in my state because they are subsidiaries of a lender. I think red sky is one.

Yet they are

RED SKY RISK SERVICES, LLC	DBA:
License #: FRNC-1237	Expires : 6/30/2026
City : HOPKINS	State : MN
Compliance Manager :	Phone : (952) 876-5397
Status : FEDERALLY REG	Compliance Manager Email: BRIAN.THOMAS@USBANK.COM

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AMC Database Search Results​

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[chad hampton]

I completely understood your complaint the first dozen times you made it. It's a problem for your business interests. It isn't a problem for the lender's legitimate due diligence functions.

Go back to the original intent of cutting the MBs out of the loop for the FRTs in 1990 and the SFRs in 2008. Same reason - the loan salesmen have no legitimate business even touching any aspect of an appraisal assignment until after it has been completed. That's the inherent and incurable conflict of interest between loan production and due diligence.

When working to specs, neither the appraisal depts at the lenders nor the AMC are operating that way. There is no conflict of interest that would compel the govt to prohibit either of them from using employees to appraise properties - as long as they are isolated from the loan origination side of the business.

As of 2025 the use of "staff appraisers" it isn't prohibited. Maybe someday govt will take the additional step and outlaw staff appraisals, too; but that day is not near.

You just don’t understand the concept of a third-party or a middleman. It’s OK, not everybody has ability to understand that concept.