FNMA Update requirements for less than 4 months

[Tom D]

be sure to add data to the appraisal, besides just checking the box. the concern always, has market condition changed. so i add current market charts from the MLS. also, do a 1oo4mc, which should show you current values are flat at worst. our MLS has monthly market news which shortcuts looking for market news. what you put in depends on the overall quality of your work.

 

[Terrel L. Shields]

In short, disciplinary actions are all over the board.

This is a problem and early efforts to be tough by some boards are problematic because once they have thrown the book at someone, they have to throw the book at the next similar complaint even when they think the first was worse than the latter violation. That was explained to me by an administrative lawyer years ago. If the state board acts differently for similar violations, then they risk having violated administrative laws. Kind of a catch 22, especially when the board suspects other more serious violations so they hammer that one person disproportionately then are reluctant to treat anyone differently. Also, the identical violation done by a trainee or licensed appraiser will draw a harsher punishment when the Cert General is involved, especially if the CG signed off on a flawed report by a trainee...which explains a lot why of CGs want nothing to do with training anyone else. So basically, a CG will need to spend as much time on a trainee's report they sign as if they did the report sans trainee and got to keep the whole fee.

 

[TerryRohrer]

This is a problem and early efforts to be tough by some boards are problematic because once they have thrown the book at someone, they have to throw the book at the next similar complaint even when they think the first was worse than the latter violation. That was explained to me by an administrative lawyer years ago. If the state board acts differently for similar violations, then they risk having violated administrative laws. Kind of a catch 22, especially when the board suspects other more serious violations so they hammer that one person disproportionately then are reluctant to treat anyone differently. Also, the identical violation done by a trainee or licensed appraiser will draw a harsher punishment when the Cert General is involved, especially if the CG signed off on a flawed report by a trainee...which explains a lot why of CGs want nothing to do with training anyone else. So basically, a CG will need to spend as much time on a trainee's report they sign as if they did the report sans trainee and got to keep the whole fee.

I know of a complaint that was filed against a sitting board member. That complaint was dismissed with prejudice at the screening stage (no investigation). Part of the complaint was evidence that the appraiser was in another state on the date he certified he completed the inspection of the subject.

During defense against the last complaint against me, I requested the number of complaints that had been filed against active board members and the resolutions to those complaints. There was no chance they were going to provide that information, citing privacy concerns (how is that a concern from a list of numbers not attached to any names?). The closest I got was an offer to meet with the state attorney and the administrative judge "off the record" to talk about it. Part of my response to their proposed action against me was that their actions were arbitrary and capricious. They weren't about to provide me the evidence proving that.

 

[Terrel L. Shields]

Well, in AR one board member resigned over the complaint against him. Another was whacked and the story I had was he appraised a butcher shop and called the attached refrigeration units to the cooler "real property" but another appraiser (who filed the complaint) said the building was just a shell and did not include the cooler in the value. Well, if a renter owned the freezer...yeah, it is a trade fixture. But if it is owned by the landowner, it is real property. So I think the guy was unfairly sanctioned. This was supposedly an owner-operated building.