- Apr 4, 2007
- Professional Status
- Certified Residential Appraiser
I for one, but I think we all made a huge mistake that can't be undone. I, along with everyone I know, internet and in-person always say "at capacity" for appraisals they don't want to do for $275, $350, $400 etc. We would all do these difficult assignments for $3,000 but zero market participants are willing to pay that and we know it. So we just say, "at capacity"
This recorded message, millions of times over is plenty of proof enough to show a real shortage to regulators. It's a shortage we made up, but it is real on paper as the message came from us.
I have now started saying "fee insufficient for time involved." Probably started doing this 1st of the year.
Just me alone, I have probably made the excuse, "at capacity" 15,000 times at least over the past 5 years.
Section 1119 of Title XI authorizes the Appraisal Subcommittee (ASC), after making certain findings and with the approval of the FFIEC, to grant temporary waivers of any requirement relating to certification or licensing of individuals to perform appraisals under Title XI in states or geographic political subdivisions of any states where there is a shortage of appraisers leading to significant delays in obtaining appraisals in connection with FRTs.7 These temporary waivers may provide regulated institutions lending in affected areas with access to more individuals eligible to complete the appraisals required under Title XI, which may help alleviate some of the
cost and burden associated with having a shortage of state certified or licensed appraisers in affected areas.
i can understand this point of view/action however it makes me wonder - where are lending institutions going to find non-licensed people to perform appraisals? it's not like there is an ASC.gov for unlicensed appraisers. i know they are out there, just don't know how to find them since it was never a topic/issue. i suppose agents/brokers could perform this task but i can only imagine the fee conversations...
.="TRESinc, post: 2769795, member: 136854" . i suppose agents/brokers could perform this task but i can only imagine the fee conversations..