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Interagency Advisory On The Availability Of Appraisers

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DWiley

Elite Member
Joined
Apr 4, 2007
Professional Status
Certified Residential Appraiser
State
Tennessee
https://www.FDIC.gov/news/news/press/2017/pr17042.pdf
 

gregb

Elite Member
Joined
Sep 3, 2011
Professional Status
Certified General Appraiser
State
California

Most interesting aspect of this announcement:

The requesting party must provide evidence of the shortage of appraisers in a geographic area and must demonstrate that the scarcity of appraisers has led to significant delays in the performance of appraisals on FRTs in that area. While an individual regulated institution may submit a request, the waiver request would apply to the affected geographic area. If granted, the requirement to use a certified or licensed appraiser on FRTs would be waived for all regulated institutions engaging in FRTs in the affected geographic area, regardless of who initially requested the waiver.
 
D

Deleted member 134708

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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. I would have done those 15,000 assignments for $2,000, not the $275 they were willing to pay and not a cent more. So essentially, I was 1 appraiser off the market....at $275. At $2,000 I would be a +1 on the market.
 
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gregb

Elite Member
Joined
Sep 3, 2011
Professional Status
Certified General Appraiser
State
California
Note that the FDIC stops short of compelling states to offer reciprocity agreements to appraisers, as it only comments on states that currently offer those agreements.
 

Evincere

Elite Member
Joined
Dec 30, 2002
Professional Status
Certified Residential Appraiser
State
Florida
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.

:clapping:
Your post should be made a "sticky" as well. And this thread should be kept alive in the General Discussion thread for all Appraisers to see. Going forward, this "shortage" misrepresentation can be undone if Appraisers become more truthful as to why they are really declining orders. Doing so would also dispel the illusion that orders that are not accepted at low fees are because they are NOT the fees they normally WOULD charge for a particular assignment.

If we can talk and complain about it here we need to start being more assertive and not just "talk"

And If those seeking to pigeon hole C&R floors and ceilings want to continue with their surveys, that's their prerogative to do so. There is no law that says we must acquiesce to fees on the same levels they were 10 years ago.
 
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TRESinc

Elite Member
Joined
Dec 1, 2011
Professional Status
Licensed Appraiser
State
Ohio
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...
 

gregb

Elite Member
Joined
Sep 3, 2011
Professional Status
Certified General Appraiser
State
California
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...

Loan officers, loan processors and underwriters, AMC monkeys...
 

LANoble

Sophomore Member
Joined
Jun 5, 2015
Professional Status
Certified Residential Appraiser
State
West Virginia
Well, this could very well be a no go because if AMCs can't and won't pay appraisers a reasonable fee who are already certified to serve these rural areas, imagine the cost to pay someone to come from out of state.
They never addressed the real issue in the first place. Very odd really.
 

Evincere

Elite Member
Joined
Dec 30, 2002
Professional Status
Certified Residential Appraiser
State
Florida
="TRESinc, post: 2769795, member: 136854" . i suppose agents/brokers could perform this task but i can only imagine the fee conversations..
.
Yea. at 6% of the purchase/contract price and no doubt NAR would fight for it after offering a new category of expert "evaluation" designations to their members. Money talks. Would probably eliminate any Contract Price vs market value problems.:whistle:
 
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Evincere

Elite Member
Joined
Dec 30, 2002
Professional Status
Certified Residential Appraiser
State
Florida
Loan officers, loan processors and underwriters, AMC monkeys...
It would be a fun free for all to sit back and watch. All the opportunists will be jockeying for position, sitting on the fence waiting to pounce.
 
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