Illegal In House Valuations

[George Hatch]

USPAP isn't nice. Or empathetic. Not putting in the emotional labor.

I guess that makes USPAP a fascist. Either that or USPAP has internalized misogyny.

 

[Gobears81]

My wife watches the K-dramas, and I remember on one show, someone was talking about well-respected professions, like doctors, lawyers, or appraisers

 

[chad hampton]

There’s no problems with banks having staff appraisers. of course AMC‘s aren’t permitted to have staff appraisers go appraise properties, that would be a violation of their third-party responsibilities.

 

[George Hatch]

Citation needed. An actual prohibition which is either explicitly stated or directly implied. Just because managing a panel is a qualifying criteria that puts an entity under that jurisdiction as an AMC doesn't mean that also maintaining a staff is prohibited. If it's even possible for the two conditions to exist at the same time then that much is self-explanatory.

 

[George Hatch]

My wife watches the K-dramas, and I remember on one show, someone was talking about well-respected professions, like doctors, lawyers, or appraisers

They're still big into corporate status and culture. Bowing to their company's royalty and such.

 

[Terrel L. Shields]

but it should be less about the value, and more about things like how good is the value, what is going on in the specific market and segment, what is the appropriate LTV, stuff like tha

The loan officer vets the credit score and applies the rules that the bank abides by. And the board has an obligation to value the property on the basis an appraisal and evaluate the borrower on the basis of past history, credit score and net worth. The riskier the venture the more skin in the game is required by the borrower usually. That's why a home loan of 90% might be common while a commercial loan might be 70% or lower. I remember when banks rarely lent more than 50% of a land purchase for farmers except in FmHA loans.

 

[chad hampton]

Citation needed. An actual prohibition which is either explicitly stated or directly implied. Just because managing a panel is a qualifying criteria that puts an entity under that jurisdiction as an AMC doesn't mean that also maintaining a staff is prohibited. If it's even possible for the two conditions to exist at the same time then that much is self-explanatory.

third-party requires three parties. When you start to count, you start with a one then a two than a three.

How’s that for a citation?

 

[George Hatch]

Not a citation. If you had something you would be able to cut-n-paste. Except you don't have anything. You have nothing.

The offense you wish existed is a legal prohibition against the use of appraisals prepared by employees of an AMC or a lender.

If you were capable of articulating every element of such an offense you wouldn't even need a lawyer. You could just file a complaint, same as anyone else. But it's already been 15 years and neither you nor any other appraiser has submitted a complaint about the existence of in-house staff appraisers to the regulators. Leastwise not a complaint that had any legs, if any complaint has ever been made in the first place.

If you had any legal recourse there are any number of anti-capitalism groups who would haul your water for you. Or you could sic the worm farmer on them, or the Guild. Or the Brookings Institute and the cat lady.

Like I said, you've got nothing. Except some wishful thinking. Now don't get me wrong, I've got some wishful thinking going, too. I wish there was a legal remedy in here somewhere that would protect the economic interests of fee appraisers to the exclusion of everyone else's rights. Whether it was centered on the permissibility of in-house staff appraisers or any other element of the current economic environment for the market for appraisal services. Because if there was arbitrary safe harbor then I would say so and encourage you and anyone else to pursue it.

 

[Fernando]

I've been writing USPAP once a week for the last 30 years and have never gotten a reply. I've concluded they're either rude or just don't bother to read their mail.

If your style of writing is distasteful like toward Nando, no wonder they don't respond.
At least Nando is not rude.

 

[djd09]

mozillo really missed out...