TD Morgan
Junior Member
- Joined
- Apr 18, 2011
- Professional Status
- Certified General Appraiser
- State
- Oregon
The Appraisal Foundation and its associated boards are private entities. If approached with an issue with which they don't want to deal, they will ignore their responsibility to the appraiser profession. The one time in 25 years that I needed their involvement, they were not responsive.
They have developed their educational Alliance for Valuation Education. If they want to get into the business of appraiser education, how can they also be the authority that provides qualification standards? Isn't that prima facie evidence that TAF is self-serving?
So my question is this:
Is it time to promote the dissolution of the foundation's oversight authority? No one could actually force its formal demise or dissolution, what is being requested is actually removing all its authority to force states to follow its dictates.
It would likely require Congress establishing a formal oversight board that is run by the government (or is otherwise under the direct supervision and control of Congress, rather than operate as a private entity.)
While I would think the ASC could take over the authority, they currently don't have the ability to dictate any actions over TAF. They currently have no teeth to force any actions whatsoever. They just create an annual report that they send to Congress.
[For those who aren't aware, Title XI of FIRREA created the Appraisal Subcommittee (ASC) of the Federal Financial Institutions Examination Council (FFIEC) to oversee and monitor appraisal standards. It seems, however, as if they have given up their direct authority, based on the response give to me from them.]
They have developed their educational Alliance for Valuation Education. If they want to get into the business of appraiser education, how can they also be the authority that provides qualification standards? Isn't that prima facie evidence that TAF is self-serving?
So my question is this:
Is it time to promote the dissolution of the foundation's oversight authority? No one could actually force its formal demise or dissolution, what is being requested is actually removing all its authority to force states to follow its dictates.
It would likely require Congress establishing a formal oversight board that is run by the government (or is otherwise under the direct supervision and control of Congress, rather than operate as a private entity.)
While I would think the ASC could take over the authority, they currently don't have the ability to dictate any actions over TAF. They currently have no teeth to force any actions whatsoever. They just create an annual report that they send to Congress.
[For those who aren't aware, Title XI of FIRREA created the Appraisal Subcommittee (ASC) of the Federal Financial Institutions Examination Council (FFIEC) to oversee and monitor appraisal standards. It seems, however, as if they have given up their direct authority, based on the response give to me from them.]
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