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Kentucky Appraisal Board warning to AMCs

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Mike Kennedy

Elite Member
Joined
Sep 28, 2003
Professional Status
Certified Residential Appraiser
State
New York
Memorandum to Kentucky Registered AMCs Regarding Appraiser Independence, Objectivity, and Impartiality



http://appraisersblogs.com/appraisa...logs+»+Appraisal+news+at+AppraisersBlogs.com)
 
See the comment below the story?



Memorandum To Kentucky State Appraiser’s Board

If my memory serves me correctly you are the group that stated three years ago that HVCC will do no harm. Your canned comment for all appraisers was: “It’s not a law so it can’t hurt us”. How’s that theory working now that HVCC has morphed into something just as bad?

Congratulations on your new found wealth. Glad to see that someone is making great money off of AMCs. Glad to see that you gloat over it on the homepage of your website.

Hint: Perhaps you should turn your attention to helping appraisers now. Don’t worry, you’re right up there with the AI in that department. They too feel no obligation to assist appraisers who pay dues each year. Ever considered a C & R Fees Law? I didn’t think so.



The appraiser making the comment needs to brush up on the KY appraisal board law.

1) The purpose, role and mission statement of the KY board (and every other board in the US) is NOT to assist, help and protect appraisers. It never was. Every appraisal board in the US was created because they were REQUIRED to by FIRREA and federal law.

2) Most state appraisal boards (not sure if there is even one) do not have statutory authority to set appraisal fees, a fee schedule, minimum fees, maximum fees or any other kind of fees.


I am not and never have been a fan of any appointed member of my state appraisal board......but I surely don't expect them to embark on a mission outside of their statutory responsibilities.


Please appraisal boards.....don't help me. Just do your job and enforce the regulations in place and revoke the license of every appraiser that is found guilty of fraud or any intentional ethics violation....including forgery, created comps and signing a certification that in untruthful.
 
I'm sure that the appraiser who wrote the memo needs all the help he can get--very shoddy reasoning (misunderstanding the role of a state board and the AI--they can lobby but can't strong arm anyone to do anything--that whole free enterprise thing ya know).
 
This company will be able to claim plausible deniability to the next state who calls them out on such procedures, and neither state will be the wiser.

At best, a fifth of the states will pressure in response to these approaches.

What you can count in is an AMC complying in one place, and pushing the envelope with non compliant engagement elsewhere, as enforcement actions dictate.

The fact they have been informed about the proper ethical approach really does not mean a thing outside of KY.

My crystal ball is working again this afternoon;

I forsee a concerted effort to overwhelm state enforcement by making each state set every single detail regarding approach, while the AMC pushes all fronts without being proactive regarding supplied ethical information from state to state.
 
The Shoe Is On The Other Foot, And

...it doesn't fit!

Contrary to the above poster, I see this as the first step towards the end of AMCs as we now know them. As currently constituted, they will never make money if they have to comply with USPAP (and other appraisal regulations as well).
 
Meh. Maybe it's a start...
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