Illinois Board Issues Warning On Hybrid Appraisals

[George Hatch]

Well, if you haven't yet bothered to develop any of your other alternatives then I guess you had best do what you're told.

 

[Mr Rex]

I think what I would say about the role of an appraisal board member is that they need to know what USPAP says and they need to know what their state's rules and regs say.

Meaning, if the state has rules/regs applicable to the activity of "inspecting" then whomever is performing that activity would be subject to those rules/regs.

I'm not familiar with the applicable rules/regs of IL. But it seems to me that if their rules/regs require people performing a non-technical inspection such as an (insurance or title company inspector would perform) to be licensed at some level specifically *for that activity* then those rules would apply just as much to appraisers as anyone else. What would make an appraiser exempt from their "inspecting" licensure requirements?

Will IL appraisers be required to obtain and maintain this additional qualification - which they currently lack?

Will IL require appraisers be required to be Licensed Home Inspectors of have equivalent training or is Mr Weaver talking out of the Appraiser advocate side of his mouth? Will IL require the same level of licensure for the providers of comp data in the MLS? Again, both sides of the mouth. I am not a fan of the bi fur reports, but over stepping is over stepping. Want to prevent it? Campaign for changes to USPAP. It should be relatively easy, they almost arbitrarily change non issues every 2 years. If this is a real issue, it should move to the fore front and be addressed even if mid publishing cycle of the "revised" new USPAP. I doubt any residential appraiser would bat an eye to pay for a new USPAP book or a 7 hour update if the powers that be made it so.

 

[djd09]

USPAP is so weak, that it allowed the last financial collapse. enough said.

maybe that is why there is no mention of physical inspection. hee haw hee haw.

 

[chad hampton]

What makes somebody a “USPAP expert”? Is that even a title? Is it the fact that you own the book, or are able to read, or is it a combination of the two?

You can use USPAP to argue for and against almost any issue. There are plenty of clear examples in USPAP as to why the appraiser is the only one that’s permitted to do an inspection for appraisal purposes. Just like there’s plenty of examples and USPAP as to why an inspection is not necessary.

The fact that USPAP does not require an inspection doesn’t even apply with regards to hybrids, since an inspection is being performed. I’m a little surprised people keep bringing that up. Once an inspection is required by the client for valuation purposes, it now becomes the question of who would be the logical person to do said inspection.

USPAP also sets the min standards. States are well within their right to clear up the mess that is USPAP. Some states are choosing to do that. Don’t forget who the state boards are here to protect. Not appraisers or AMCs.

 

[George Hatch]

Will IL require appraisers be required to be Licensed Home Inspectors of have equivalent training or is Mr Weaver talking out of the Appraiser advocate side of his mouth? Will IL require the same level of licensure for the providers of comp data in the MLS? Again, both sides of the mouth. I am not a fan of the bi fur reports, but over stepping is over stepping. Want to prevent it? Campaign for changes to USPAP. It should be relatively easy, they almost arbitrarily change non issues every 2 years. If this is a real issue, it should move to the fore front and be addressed even if mid publishing cycle of the "revised" new USPAP. I doubt any residential appraiser would bat an eye to pay for a new USPAP book or a 7 hour update if the powers that be made it so.

USPAP is supposed to reflect our understanding of what it takes to render professional appraisal services, not to drive that understanding or to dictate that understanding to us.

What fundamental appraisal principles would we cite in support of an urgent need to outlaw desktop appraisals across all appraisal disciplines? Because whatever overriding principle it is that would drive a prohibition of the no-look appraisal would apply equally to the no-look appraisal review.

This is a user-driven emergency (if you want to call it that). If we want to bring the power of the State to bear on what some of our clients are and are not permitted to use in these transactions then it seems to me that its the lenders' regulators who would be in a position to do that.

 

[J Grant]

USPAP is supposed to reflect our understanding of what it takes to render professional appraisal services, not to drive that understanding or to dictate that understanding to us.

What fundamental appraisal principles would we cite in support of an urgent need to outlaw desktop appraisals across all appraisal disciplines? Because whatever overriding principle it is that would drive a prohibition of the no-look appraisal would apply equally to the no-look appraisal review.

This is a user-driven emergency (if you want to call it that). If we want to bring the power of the State to bear on what some of our clients are and are not permitted to use in these transactions then it seems to me that its the lenders' regulators who would be in a position to do that.

A change in USPAP would not "outlaw desktop appraisals". A change in USPAP could define an inspection when done for appraisal purposes as appraisal practice.

 

[George Hatch]

What makes somebody a “USPAP expert”? Is that even a title? Is it the fact that you own the book, or are able to read, or is it a combination of the two?

Forget expertise, let's just refer to competent. What would make you or I or anyone else competent with the material? The same criteria that would apply to appraisal competency, right?

You can use USPAP to argue for and against almost any issue. There are plenty of clear examples in USPAP as to why the appraiser is the only one that’s permitted to do an inspection for appraisal purposes. Just like there’s plenty of examples and USPAP as to why an inspection is not necessary.

I challenge you to cite even one passage in USPAP that speaks to an appraiser being the only one permitted to inspect OR which speaks to an inspection not being necessary.

What I know of USPAP is that it doesn't address the topic either way.

The fact that USPAP does not require an inspection doesn’t even apply with regards to hybrids, since an inspection is being performed.

I’m a little surprised people keep bringing that up. Once an inspection is required by the client for valuation purposes, it now becomes the question of who would be the logical person to do said inspection.

I wanna see you expand on your reasoning here. If USPAP itself doesn't require an inspection to begin with then how can it require that inspections only be performed by an appraiser? If a client can require an inspection then how does that translate into the client requiring that inspection can only be performed by an appraiser?

USPAP also sets the min standards. States are well within their right to clear up the mess that is USPAP. Some states are choosing to do that. Don’t forget who the state boards are here to protect. Not appraisers or AMCs.

No argument there. I would only remind you that the manner in which a state would add additional requirements would be in the form of a law, rule or regulation - passed at the legislative level and not unilaterally imposed at the administrative or executive level. A mayor or city manager in a town cannot arbitrarily enact a rule prohibiting kissing in public - they have to go through the legislative process to get such an ordinance passed.

Trust me when I tell you that there are some really good reasons for the enforcement branch of the local, state and federal branches of government stay out of the legislative functions. A regulator's job is to enforce the existing rules the way they are written, not to create new rules on the fly. So yeah, not only is it not the appraisal board's job to protect your economic interests, it's actually *unethical* for them to do it.

 

[George Hatch]

A change in USPAP would not "outlaw desktop appraisals". A change in USPAP could define an inspection when done for appraisal purposes as appraisal practice.

How? How would you go about doing that? By changing a definition to mean what you want it to mean instead of what the actions of the individual and the expectations of the user really are?

 

[djd09]

I guess you had best do what you're told.

always trying to tell me what to do. we could negotiate a salary.

 

[djd09]

What makes somebody a “USPAP expert”?

yeah. taf thinks GLA is a fact. they are deep in the bubble.