It was in the OP. They are taking comments (as required by law) before they move forward with implementing such. I'm 100% confident that the comments, while largely critical (as seen from previous draft comments), won't change the direction they are heading.
I said it in the OP, but CR appraisers know all too well that incompetence is not rooted out like USPAP and state board enforcement thereof would have one believe. That isn't acceptable, but PAREA and lowering the qualification requirements won't make this better.
If they're in process of lowering the barrier to entry, I don't have much reason to believe they won't soon change the exam content/difficulty as well.
Have you ever considered if you're over qualified for this position these days? I'm pretty sure you are. Stop making sense!
Please may I kindly respond to your astute points;
A. They press delete on every comment which does not fit their pre conceived pre planned agenda. The only thing appraiser comments are good for is to tell the trade group managers how utterly incompetent and corrupt they are. Hell yes I'll write another letter.
B. Yep, that's what the FNMA CU system was supposed to accomplish, an automatic identification of systemic patterns of incompetency and fraud. What they found was exactly what we told them they would find; insurmountable AMC issues that created systemic brain drain and such. The pattern recognition is there for absolutely sure. Just search 'appraisal typing service' online. That is the staple method of volume producing appraisers whom churn grossly disproportionate volume through the CU system. The GSE managers understand the scale of the problem. But as they are not honestly objective and really don't care about risk management, they buried the entire thing in a process of advocacy for what the lenders wanted; Production without the impediment of the appraisers independence. So now manual underwriting is for the most part; gone. Required field reviews; gone. Third party independent validation the appraisers work product was not altered or falsified; gone. The intended primary function of the CU to identify appraisers committing fraud; Never materialized in the first place. The Appraisal Coach would have gone first. Identifying non unique work product efforts and rubber stamping type activity; Same deal, never materialized. They'd of had to shut down the top ten AMC's for the top ten lenders in this country! It's over dude.
C. Bet your bottom dollar that examinations will get easier. You can count on that. The goal is to artificially boost the appraiser workforce, in order to serve the lenders interests. In their hubris, not even pretending to try and fix the market conditions which led to continued licensee attrition. The irony of people whom claim to be market analysis experts and ethical compliance experts in the same breath, blatantly ignoring the obvious and current market conditions which inhibit small business growth and traditional training apprenticeship models. Grade A idiots. Dollar signs in their eyes. Drunk on the power.
These are culture issues, specifically the culture of people and behavioral adaptation at the appraisal trade groups. They failed to represent for small business owners and sole proprietors. They failed to hold each other accountable. They failed to maintain separation from special interests or be even remotely independent. I remember my personal shock when I really finally became educated on this industry; You mean to tell me the people running this don't even have appraisal licenses!? They have no problem falsifying test scores. That was too easy to get caught up with though, so why wouldn't they take another route and lock in something easier. They don't even pretend to keep up the illusion of a program with integrity anymore, which is why, as Johnathan Miller's recent articles highlights; There has been non stop lawsuits and embarrassing discovery. What they hope for is that no one pays attention, which is one of the benefits of a restrictive program thus far. What they're likely count on for the back end of total open door reform, is the positions being diluted to such a degree that people primarily only maintain licenses as employees, and they really will not be inclined to pay attention or care what happens with the industry.
Perhaps you've heard the term recently; 'the franchise model.' These stone cold liars say this with a straight face. Talking non nonchalantly like running an appraisal business is just like any other regular business which it is not. You can not have appraisal independence if everyone with a license is an employee of a corporate business or mega firm type deal. The entire reason the now defunct strict appraisal process rules were out there, was to assure independence. They put strict prohibitions on employee appraisers working for lenders. Because that was the catalyst for the steamrolling fraud that grew out of control. You need your appraisers to be sole proprietors, otherwise they'll be susceptible to all the pressures of predatory lending. It goes down like this; Lender to AMC manager; Get your appraisers in line or we'll replace you both. (Sub out any different combination of engagement, it's all the same.) 'Franchise appraisal firm owner' to his staff; You guys better stop killing all these deals or we'll lose this client and nobody will have any work. One of my favorite lines was a m c related. 'When you upset someone at the a m c, you don't just lose one client connection, you lose them all, with an additional bonus of having a silent black list propagate to every lender that AMC works with, past, present, and future.
Last one out don't forget to turn off the lights.
People don't get this one. In one of the original appraisal bias lawsuits, the appraiser was accused of racism for complementing the home owners efforts to clean up the old junk and get things in nicer order again. He said; You really cleaned this place up well. And now seventy thousand licensees have to take bias training forever. The rule change proposals do however move this to a five hour class. I think they could see the idiocy of their requirements. Screwed up hours and class planning immediately. And if appraisers don't know by now, I don't know how they could not, you can do online classes in far less of the time by clicking through straight to the test, rendering redundant classes rather meaningless. I get USPAP done in about an hour every time, the other classes only a little more. Define content mastery. All the CE providers end up doing is spending most of their time chasing down individual state approvals, which is why they constantly repackage relable the same content as a new CE class. Been there done that. The CE providers earnings is off the chart, they're raking tens of millions yearly for doing not very much at all. I'm hoping Calypso does not sell out.
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