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Give appraisers their integrity back.

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That is an interesting question. Are AMC's appraisal companies or are they agents of the lender. Right now they are neither. USPAP and state boards have no control over AMC's (look at Right On Time or USAappraisals.net as an example). Here is a discredited and license revoked appraiser still making a living from his Skippy, number hitting ways with no remorse at all. I got into a "discussion" with this guy and he called me stupid for refusing to play his game. I guess he is laughing all the way to the bank.

So here we are with AMC's neither fish not fowl. Not appraisers subject to state board sanctions nor lenders subject to SEC, FNMA, and all the other alphabet soup agencies.

Should an AMC have to have an appraisal license for each state? If they are taking responsibility for the "quality" of the report then maybe so. Perhaps there should be a new licensing category with a large cash only bond placed with the state to pay fines and stiffed appraisers. If someone files a complaint with the state for an appraisal ordered by an AMC, the AMC must respond, not the individual appraiser.

Just some early morning, pre coffee thoughts...
 
How do you respond to the AMC if they are not the named Client?
 
.....GSE and investor pools(CDO's and whatever....) that are beginning to force repurchase of inadequately or intentionally unsupported appraisals WILL bring enforcements that will lead to INDIVIDUAL responsibility for work quality.........then the AMC will have to justify economically and legally their participation..........meaning we will get our fee based on experience, performance, education and an additional charge will be made to the lender for the expense of finding and coordinating the services of the appraiser and that expense or fee will be added to the mortgage processing costs to the lender, ie: the borrower, and not taken from the appraisers' charge for services...different route of income for all involved, but that establishes the chains route of liability...........currently the GSE's and such blame the mortgage or lenders companies for improper performance and they, the lenders say they did nothing wrong because this works of paper was submitted for their approval and the Over or government lenders did not do their inspection job----so none is in error on these default....just the borrower who has all the liability due to his activity in the purchasing market...........but all of this WHO IS question is being resolved in AGeneral offices and courtrooms around the country...........the coming lawyers of suit will bust the AMCs as now configured when losses accumulated to the public's pension and revenue pockets.....the results shall be an appraiser and works will become more or less credible to the process........if less, fees will be dictated by AMC's............but if more, then the AMC will be looking to us for OUR approval to do business with and for them.........due to the lenders' resulting liability for our performance of process........without this liability attached through our work our being a bit of a player will remain.......no pay pain above, no pay gain below.........best to all........rs
 
If you want to track this legislation you need to track H.R. 3915 too (or instead). Some of the provisions of 3837 have been rolled into 3915. See item #2 in the summary at http://www.rules.house.gov/SpecialRules_details.aspx?NewsID=3140

I think that means the House is done with 3837 itself.
All of 3837 was adopted into 3915 as an amendment. 3837 is dead as an individual bill, only 3915 is active.
The only appraisers who need their integrity given back are those who gave it away to begin with.
That sounds nice, but it is not exactly true. When one is part of a crowd where many have no integrity, their tarnish rubs off on you no matter what your actions may be. One cannot merely say, "I am not one of them" and not have your integrity impugned.
 
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this bill would help give appraisers their integrity back
it also presumes they had it to start with. Obviously a lot of them have lost it somewhere along the line if we all started out with it.

Careful screening of all such bills so far still includes the proviso that bankers can still demand additional comps, and submit 'new' information to the appraiser for consideration....that (literally) gives them a legal foot to REQUIRE the appraiser take that step [that is, since they didn't ask for it in the first place, why do i owe them it now, post-report, simply because the value was not what they wanted or they are looking for an excuse to dump the borrower?] A request for a workfile examination should not be subtitituted with a demand to have the appraiser take another bite of the apple. And the sole purpose of 'considering' additional info or including 'additional' comps is to punish the appraiser for doing their job or to make the appraiser kowtow to the goal of increasing the value.
The only thing a lender should be able to request is to correct a factual error. nothing more. Once the report is done, its done. These current laws purporting to 'protect' the appraiser merely shift the pressure to perform from the front end of the assignment to the post-report review period. Nothing changes.
 
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