Tom Hildebrandt
Member
- Joined
- Jan 16, 2002
- Professional Status
- General Public
- State
- North Carolina
Tim
Yes, I do a lot of reviews. I do reviews for the City of Greensbor Redevelopment Commission and I often do reviews for litigation clients.
Your coments are very germaine. If the facts are wrong, they should be easy to prove. The easiest of all is the made up comparable. This is not hard for an investigator to prove wrong.
The problem is when the investigator says "Here are three sales that he/she could have used that would have led to a different value conclusion." This type of comment is what the boards are saying is a "statement of fact." No discussion of why the sales would be comparable, no discussion of what the appropriate adjustments would have been, no proof of quality condition, etc, etc. In one notable instance, an investigator reported that the basement adjustment was wrong, but when queried, he said he had done no market research in the area but in his home area (200 miles east) the adjustment would have been wrong.
Scary? These are the guys testifying that you are a "bad appraiser" and they provide their comments to the legal staff on a daily basis without documenting word one in a work file.
Under the NCAB system, the investigator does not have to prove the sales to be good comps, the appraiser has to prove that they are bad comps. He also has to prove his adjustments are correct. In fact, he has to prove that almost anything he did could not be argued in a different manner, otherwise he is guilty of "bad appraising."
You state that you hope any every state board can recognize the difference between a fraud, bad appraisal practice and a difference in opinion. You may find this hard to swallow, and I did not believe it the first time I sat through a NCAB board hearing but it is true. The NCAB board is incredibly inept in this regard, and the investigators are not much better.
In short, they talk a good story, but they do not know beans about USPAP and good appraisal practice.
Regards
Tom Hildebrandt GAA
Yes, I do a lot of reviews. I do reviews for the City of Greensbor Redevelopment Commission and I often do reviews for litigation clients.
Your coments are very germaine. If the facts are wrong, they should be easy to prove. The easiest of all is the made up comparable. This is not hard for an investigator to prove wrong.
The problem is when the investigator says "Here are three sales that he/she could have used that would have led to a different value conclusion." This type of comment is what the boards are saying is a "statement of fact." No discussion of why the sales would be comparable, no discussion of what the appropriate adjustments would have been, no proof of quality condition, etc, etc. In one notable instance, an investigator reported that the basement adjustment was wrong, but when queried, he said he had done no market research in the area but in his home area (200 miles east) the adjustment would have been wrong.
Scary? These are the guys testifying that you are a "bad appraiser" and they provide their comments to the legal staff on a daily basis without documenting word one in a work file.
Under the NCAB system, the investigator does not have to prove the sales to be good comps, the appraiser has to prove that they are bad comps. He also has to prove his adjustments are correct. In fact, he has to prove that almost anything he did could not be argued in a different manner, otherwise he is guilty of "bad appraising."
You state that you hope any every state board can recognize the difference between a fraud, bad appraisal practice and a difference in opinion. You may find this hard to swallow, and I did not believe it the first time I sat through a NCAB board hearing but it is true. The NCAB board is incredibly inept in this regard, and the investigators are not much better.
In short, they talk a good story, but they do not know beans about USPAP and good appraisal practice.
Regards
Tom Hildebrandt GAA