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First Domino Has Fallen

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Alan, what is your relationship with the Appraiser you filed the complaint against? Ex-wife?

Wow, I’m flattered !

I didn’t realize this forum was THAT kind of forum.

Are you looking for a little action? Maybe a naughty boy? Want to borrow my tape measure? You’re music indicates a hopeless romantic. If you post a recent photo of “hot Ms. Janet” then you might get some action. Maybe even attract an MAI/SRA looking for a little TNA.

It's just that your reaction to the dismissal of the complaint seems completely out of proportion. I don't get it.

Out of proportion? This is Texas. Everything is bigger in Texas.

The FHA appraisal assignment management is a scam in which the honest appraiser is hurt and the dishonest appraiser is rewarded. The corruption appears to go to the top of the appraisal industry. The financial impact is significant to many people, both pro and con. There is also the pesky issue of complying with the regulations. I find it fascinating (and entertaining) when the regulatory agencies / HUD staff attempt to justify what is going on and make a fool out of themselves trying to do so.

The issue affects many innocent appraisers and is worthwhile to pursue.

The real question is why are so many people in denial and trying to cover it up ?
 
This is the canned response from the Appraisal Subcommittee staff when contacted about state regulatory agency issues:

Thank you for your email. Title XI of the Financial Institutions Reform, Recovery, and Enforcement Act of 1989, as amended (Title XI), authorizes the Appraisal Subcommittee of the Federal Financial Institutions Examination Council (ASC) to oversee State appraiser regulatory programs (Programs) to determine whether they comply with Title XI. However, Title XI does not authorize the ASC to act in the capacity of a court of appeals for actions taken by States. Nor does it authorize the ASC to provide appraisal or case reviews for individuals.

We will include your correspondence for consideration during our next Compliance Review of STATES's real estate appraiser program for the purpose of evaluating compliance by the State with Title XI in the investigative and enforcement process.

In a follow up message the ASC Staff stated:

Yes, currently TALCB is on a 2 year compliance review cycle. Yes, the last TALCB compliance review was in Feb 2016 and the next TALCB compliance review is scheduled for 2018. We are constantly working with our states between reviews on maintaining compliance with Title XI.

The TALCB issues have been reported to the ASC Staff.

The ASC Staff were asked if they have a response.

The ASC Staff have not provided any significant response or taken any noticeable action.

They gave you their response: " Title XI does not authorize the ASC to act in the capacity of a court of appeals for actions taken by States. Nor does it authorize the ASC to provide appraisal or case reviews for individuals."
 
They gave you their response: " Title XI does not authorize the ASC to act in the capacity of a court of appeals for actions taken by States. Nor does it authorize the ASC to provide appraisal or case reviews for individuals."
A rational response means nothing to someone who is not acting in a rational manner.
 
"Suitability of Soil
The Appraiser must consider the readily observable soil and subsoil conditions of the site, including the type and permeability of the soil, the depth of the water table,
surface drainage conditions, compaction, rock formations and other physical features that affect the value of the site, or its suitability for development or support of the
existing improvements.The Appraiser should also consider events and published reports regarding the instability of the soil and surface support of the land as related to the subject and
proximate properties. The Appraiser must analyze and report how this would affect the Property."
https://portal.HUD.gov/hudportal/documents/huddoc?id=40001HSGH.pdf

Did the appraiser disclose they are not a Geologist.
Did the board explain how to observe subsoil conditions without digging.
 
"Suitability of Soil
The Appraiser must consider the readily observable soil and subsoil conditions of the site, including the type and permeability of the soil, the depth of the water table,
surface drainage conditions, compaction, rock formations and other physical features that affect the value of the site, or its suitability for development or support of the
existing improvements.The Appraiser should also consider events and published reports regarding the instability of the soil and surface support of the land as related to the subject and
proximate properties. The Appraiser must analyze and report how this would affect the Property."
https://portal.HUD.gov/hudportal/documents/huddoc?id=40001HSGH.pdf

Did the appraiser disclose they are not a Geologist.
Did the board explain how to observe subsoil conditions without digging.


https://www.nrcs.usda.gov/wps/portal/nrcs/main/soils/survey/

.
 
What's that?

The link to help you answer most of these questions

"Suitability of Soil
The Appraiser must consider the readily observable soil and subsoil conditions of the site, including the type and permeability of the soil, the depth of the water table,
surface drainage conditions, compaction, rock formations and other physical features that affect the value of the site, or its suitability for development or support of the
existing improvements.The Appraiser should also consider events and published reports regarding the instability of the soil and surface support of the land as related to the subject and
proximate properties. The Appraiser must analyze and report how this would affect the Property."
https://portal.HUD.gov/hudportal/documents/huddoc?id=40001HSGH.pdf

Did the appraiser disclose they are not a Geologist.
Did the board explain how to observe subsoil conditions without digging.
 
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