Evaluations & USPAP - Question from a bank staff appraiser

[BRCJR]

Makes sense. But what about State law and State bank regulators in Wisconsin? I don't know. State Bank Regulators and State laws differ. Even if a Federally Insured lender operates in a State, the State still has control. A Federally insured institution still has to be licensed with the State they are doing business in.

They are audited by both federal and state regulators.

Appraisal rules differ among states.

I guess what I am asking is "does IAEG control state government?"

Interagency Appraisal and Evaluation Guidelines
I. Purpose
The Office of the Comptroller of the Currency (OCC), the Board of Governors of the Federal Reserve
System (FRB), the Federal Deposit Insurance Corporation (FDIC), the Office of Thrift Supervision
(OTS), and the National Credit Union Administration (NCUA) (the Agencies) are jointly issuing these
Interagency Appraisal and Evaluation Guidelines (Guidelines), which supersede the 1994 Interagency
Appraisal and Evaluation Guidelines. These Guidelines, including their appendices, address
supervisory matters relating to real estate appraisals and evaluations used to support real
estate-related financial transactions.¹ Further, these Guidelines provide federally regulated
institutions and examiners clarification on the Agencies’ expectations
for prudent appraisal and evaluation policies, procedures, and practices.

 

[Ricky LaFleur]

With the various opinions and positions on Evaluations---all I can say is they are legal and lenders use them.

If nothing in your state law prohibits:

A commercially competent residential Appraiser would do well to contract with local lenders and do commercial Evaluations on properties with transaction values up to 500,000.

They can be done in less time than a URAR at twice (or more) the fee.

Do not like them do not do them, period.

Fight the change, swim against the current, do what you want but, the Evaluation will become a more common product, since the transaction threshold was raised to 500,000, for commercial transactions.

Added to the demand will be the loss of the CG as they age out and retire.

While a commercially competent residential appraiser could perform evaluations, so can a non-appraiser.

"One primary difference between appraisals and evaluations is who can perform them. While appraisals can be performed only by a state-certified or licensed appraiser, evaluations can be performed by a person who possesses appropriate appraisal or collateral valuation education. As such, banks can use internal qualified staff to prepare evaluations and comply with federal regulations"

Bank staff or whatever may be the cheapest option. I personally know of local lenders who use staff to perform evaluations on commercial property. While it could be worth pursuing as a res appraiser, the supply of providers for that service is not very limited.

 

[bernielomax]

We need an update you from you. Are you okay?

I am okay. Lots of great posts/perspectives from people here.

I have spent a considerable amount of time researching evaluations and talked to some others in this specific situation. I don't have a definitive answer on matter in Wisconsin.

Someone sent me this chart. I have no idea if the information is valid.

I thought is was interesting that nine states answered no to: "Does the state have jurisdiction over appraisers when providing evaluations".

 

[Terrel L. Shields]

State Bank Regulators and State laws differ. Even if a Federally Insured lender operates in a State, the State still has control. A Federally insured institution still has to be licensed with the State they are doing business in.

State chartered banks fall under the FDIC. National banks fall under the OCC.

 

[Zoe]

Interagency Appraisal and Evaluation Guidelines
I. Purpose
The Office of the Comptroller of the Currency (OCC), the Board of Governors of the Federal Reserve
System (FRB), the Federal Deposit Insurance Corporation (FDIC), the Office of Thrift Supervision
(OTS), and the National Credit Union Administration (NCUA) (the Agencies) are jointly issuing these
Interagency Appraisal and Evaluation Guidelines (Guidelines), which supersede the 1994 Interagency
Appraisal and Evaluation Guidelines. These Guidelines, including their appendices, address
supervisory matters relating to real estate appraisals and evaluations used to support real
estate-related financial transactions.¹ Further, these Guidelines provide federally regulated
institutions and examiners clarification on the Agencies’ expectations
for prudent appraisal and evaluation policies, procedures, and practices.

So the only conflict that could apply would be State law relative to the appraisal business inside the State's boundaries. Even State bank regulators don't always audit banks the same as Federal bank regulators.

 

[Zoe]

State chartered banks fall under the FDIC. National banks fall under the OCC.

That is true but State laws relative the appraisal business differ among states. Not all State chartered lending institutions are insured by the FDIC or other federal insurance agencies.

Wait, the Federal insurance agencies went broke except VA. They ran out of money. They had no more insurance money to insure the depositors. I think most of IAEG members went broke.

WE as in US bailed them out.

 

[Zoe]

I am okay. Lots of great posts/perspectives from people here.

I have spent a considerable amount of time researching evaluations and talked to some others in this specific situation. I don't have a definitive answer on matter in Wisconsin.

Someone sent me this chart. I have no idea if the information is valid.

I thought is was interesting that nine states answered no to: "Does the state have jurisdiction over appraisers when providing evaluations".

View attachment 92274View attachment 92276

I knew you were smart. Your doing your job. Proud of you.

 

[Zoe]

No, it's the same Mike. I worked at Starewide for 15 years. He was my mentor for my CR and another guy (he died years ago) at Statewide was my CG official supervisor when I earned my CG. but I still got some of my commercial hours with Mike and he was a far superior appraiser. Before Mike trained me, I worked for Susan and John Burrow as a secretary, then office manager. Mike hired me when I took Appraisal 101 from him at State Tech (now Southwest. MIike encouraged me to get my IFA and later on my ASA. He would pay a bigger split if you earned a designation, which was a good incentive for me. I never became his competition. I still call him for questions. I feel sorry for people who didn't have a good mentor like I did.

We probably had a class together with Mike then. The next time you talk to Mike, ask him if he remembers Terry Evans in Middle Tennessee.

Mike will remember Terry Evans in Middle Tennessee.

That is how long I have known Mike.

Mike remembers Terry Evans appraisal association ( different name) merging with NAIFA. We were at a meeting when they merged together.

I can't remember that guy out of Mississippi's name that gave a speech that day. Mike would remember.

 

[Tiffany Gibbons]

This may have been his father. Because Mike is not old enough to be a world war 2 vet. I thought you said the Mike you are referring to was a world war 2 vet.

I remember the name John Burrow. He may have been the one that took over the commercial side but Kim was his right arm and maybe it was her and John that took the business over. His office that his daddy owned was on elmore park rd in Bartlett. He sold it I think. Or he may still rent it.

Big guy? Pretty big boy.

JB Barnett was my commercial mentor. Mike was definitely not in WW2. He's only 10 or 12 years older than me, lol. JB and John Burrow (totally different company) that I worked in first. Both died long ago.i was the "right hand" before Kim. She's still there, she's doing well. I think he sold the building on Elmore Park. I went there every day for 15 years until 2007 when I went to Shelby County. The crash starting in 2006 I could see coming.

 

[Tiffany Gibbons]

We probably had a class together with Mike then. The next time you talk to Mike, ask him if he remembers Terry Evans in Middle Tennessee.

Mike will remember Terry Evans in Middle Tennessee.

That is how long I have known Mike.

Mike remembers Terry Evans appraisal association ( different name) merging with NAIFA. We were at a meeting when they merged together.

I can't remember that guy out of Mississippi's name that gave a speech that day. Mike would remember.

Yes, we were all in the same classes. Terry does DOT work now as far as I know.