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AQB Comment Letter From Florida

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Francois K. Gregoire

Senior Member
Joined
Jan 14, 2002
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Certified Residential Appraiser
State
Florida
Hi All,

For those of you with an interest in the future of our chosen profession and the criteria needed to become a licensed or certified appraiser, here is a link to comments provided to the AQB.

The AQB issued their Fourth Exposure Draft on Revising the Real Property Appraiser Qualification Criteria on March 10, 2003. Comments are due by June 2, 2003.

Find the file at either of the links below.

http://makeashorterlink.com/?W629211C4

http://groups.yahoo.com/group/FAR_Appraisa...005-02-2003.doc

Frank
 

George Hatch

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Jan 15, 2002
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Certified General Appraiser
State
California
Frank,

You make some very presuasive arguments.


George Hatch
 

Terrel L. Shields

Elite Member
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Joined
May 2, 2002
Professional Status
Certified General Appraiser
State
Arkansas
Amen, Frank

In my area we are fighting a desperate shortage of appraisers, especially certified general. With tougher requirements to meet, those who train appraisers are finding it too demanding and too much risk to train persons to the level required to achieve standards much higher than that now required. Those trainees, on the other hand, receive compensation that is inadequate for years. Any motivated and energetic young college grad will have an enormous problem languishing in poverty for an additional 3 -4 years just to get certified. Frankly, I wouldn't do it.

Many of us who started in the 1988-1993 era came from backgrounds that were technical, but learning curves being what they are, we were allowed to make a few mistakes and did not get the scrutiny that an appraiser gets today. Creating a mistake free appraiser in a 4 year period when that person has to be pre-occupied with trying to make ends meet and questioning their own sanity for working day and night for peanuts is not conducive to creating the professional. Our industry, by adopting college degree requirements, etc. is setting itself on a course of sunsetting the entire profession. When the baby boomers retire out of this business in the next 10 - 15 years, there will not be one-half the trained appraisers needed.

In my own one-half of a county, 12 years from now 8 of the 9 appraisers will be 65 years old or older. That one person, actually lives in Oklahoma, and she will be 50 then. In the past 12 years three of our appraisers have died. Thus, by 2015, will there even be 8 appraisers to retire (actually 2 would be 75 years old, another 73. 4 of us will be 65.)

Appraising is no more technical that it ever was. But the properties are more complex. That is clear in some of my remarks in the Commercial threads about reviewers who obviously know little about what they review. While I am all for specialists, many of us are being hounded to appraise common property that any CR or SL appraiser could handle simply because of the lack of appraisers. Further, with the standard set at $250,000 limits for SL's and ditto for commercial work by CR's, each year inflation reduces the number of properties those licensees can appraise. 'Cuse me, but I don't need to be appraising a 900 SF office building selling for $30,000 while million dollar farms are waiting weeks for me to show up. The limits on appraisers MUST be raised, with SL's & CR's allowed to do $500,000 properties without a co-signatory. That only brings it into line with inflation since those rules were enacted in 1991.

Further, by their preoccupation with so-called ethics, USPAP is being spoonfed to us on a near annual basis. There is no more dreary a class to take....sorry, but of the 5 instructors I have had, only 1 was the least bit entertaining, and I learned little. Nothing is more annoying that having to correct an instructor on a bad interpretation! I have been "taught" that not doing the income approach meant a limited appraisal....departure could not be evoked on a narrative report. A URAR is a limited report. The list goes on endlessly, and folks, even since the new instructor training, I was told by another appraiser of an instance where the instructor in a class mistated several items in the 2003 USPAP. Time consumed to take USPAP is time taken away from courses that could expand the body of my personal knowledge.

ter
 

Francois K. Gregoire

Senior Member
Joined
Jan 14, 2002
Professional Status
Certified Residential Appraiser
State
Florida
Terrel,

There's still time to submit comments. No need to make them formal, just relate the information as you have in the post.

The unintended consequences of the changes proposed need to be disclosed.

AQB FAX
202.347.7727
202.624.3053

AQB email

[email protected]

Frank
 

Bill_FL

Senior Member
Joined
Aug 23, 2002
Professional Status
Certified General Appraiser
State
Florida
Frank,

Very well written response.

I also have made comments, however they seem to be going in the same trash can as most of the other people's I have spoken with.
 

Francois K. Gregoire

Senior Member
Joined
Jan 14, 2002
Professional Status
Certified Residential Appraiser
State
Florida
Originally posted by Bill Potts@Jun 5 2003, 07:53 AM
Frank,

Very well written response.

I also have made comments, however they seem to be going in the same trash can as most of the other people's I have spoken with.
Bill and Terrel,

Thanks for taking the time to provide your comments to the Appraiser Qualifications Board.

Although I disagree with much the Appraiser Qualificaitons Board is proposing and much they have put in place, I know they do read the comment letters submitted in response to their Exposure Drafts. Each of the Exposure Drafts released after the First to Revise the Real Property Appraiser Qualification Criteria has incorporated changes; some of which were suggested in comment letters.

Post Script to my comment letter:

My comment letter described an actual application for a Florida State Certified General Appraiser. This individual has over thirteen years of appraisal experience and currently holds Certification as a General Appraiser in another state. He has earned a Bachelor of Science degree in Business Administration with a major in Finance and Economics and a Master of Arts degree in English Literature. Nearly all his appraisal education credit was earned by challenging course examinations. He has clearly demonstrated the ability to solve complex problems, however the actual number of hours of appraisal course attendance is merely 100 hours. Under the current criteria he is not qualified to sit for even the Certified Residential exam in Florida. As a result, at the June 3, 2003 meeting of the Florida Real Estate Appraisal Board, his request for waiver of the education and approval to sit for the Florida Certified General Aprpaiser Examination was denied. The AQB does not permit substitution of Experience for Education. The FREAB's hands were tied.

Another individual, a Florida State Certified Residential Appraiser with a four Year Degree in Real Estate was disciplined by the FREAB. His violations included failure to look at Comparable Sales, although his signed certification indicated otherwise, preparing misleading appraisal reports by intentionally understating the distance of comparable sales from the subject property, utilitizing summed sales (land sale plus separate retail sale of a mobile home and setup costs, and estimated value of mobile home site - owned over 5 years - plus retail sale of new mobile home) in the development of an appraisal and prepartion of an appraisal report, and failure to comply with the Record Keeping Section of the Ethics Rule.

He worked for a high volume shop. These offenses were committed while a trainee. He worked in a high volume, quick turn time shop. They did not believe it was really necessary to look at the Comparable Sales. Instead, they just snatched the photos and data from the MLS. Work files consisted of unsigned copies of the appraisal report only. No photos, no field notes, no maps, no comparable sales information, no signed certification. Kinda blows the claim of the value of an education.

Granted, these are but two anecdotal examples, but plenty more could be provided from Florida alone. If the AQB is serious about promoting and maintaining Public Trust, the value of experience should be considered. Of the two appraisers described above, which would the public be more likely to place their trust?

Frank
 

Terrel L. Shields

Elite Member
Gold Supporting Member
Joined
May 2, 2002
Professional Status
Certified General Appraiser
State
Arkansas
AGREED. But other issues are yet unresolved and just waiting to trap someone. Work File being one. What is the "Work file" - Does each folder require a copy of the MLS Sheet and Public record sheet plus "field notes"? How does one prove that the appraiser really did view the comparable? What are field notes? A sketch? Property description? will it vary from the appraisal report contents? Some lawyers recommend appraisers throw away such field notes as they can be subpoenaed by the opposition and used to trip up an appraiser?

How many such notes do I have scribbles on about a different appraisal? or diddled on them (not piddled on them, diddled) while yakking on the phone. Electronic records? Is the MLS electronic database good enough? Ours is purged after 3 years, not the five years USPAP requires. Our assessor records are also revised every 3 years, so it could change twice within that 5 year time frame. I have banker boxes full of researched comps in clear plastic holders. I have 6 file cabinets full to the brim.

I found out during the last year while I was under the threat of suit how nightmarish that can be. Had the judge not thrown the suit out, I was fixing to shut down the office for a week or more just to collect the 400 + files that was listed in the plaintiffs interoggatories (i.e.- all reports AND supporting data, files - paper or computer, and photos for the 400 or so reports that I have done for that one client.

Another issue is the "Box" placed around appraisers who move to a different state. It appears to be that it is a nightmare to get switched one to the other. With so many in my area moving freely between OK and AR while moving only a mile or two, it could be a real problem. One of my subs is going thru a divorce. She currently occupies a house 1 mi. from the Arkansas line, but if she settles likely her husband is going to get the house (his parents old ranch) and she will almost certainly have to move to Arkansas side of the line as there is so little available for sale on the other side.

Likewise, a sick or handicapped person can go to inactive state, but is not able to work during brief intervals they might be physically able and taking a CE course during long term illness is difficult. No state I know will accomodate an appraiser under such circumstance. My long time co-appraiser suffered from melanoma for 4 years and the last CE class she took put her in bed for days. But appraising kept her mind off her pending doom and she did appraisals up to 90 days before her death (she took no solid food for the last 45 days) even though her step-daughter had to drive her to the property, take the photos (she trembled so much), etc.

Licensing is a burden and is an unnecessarily harsh one at that.
 
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