Point of Order
It was not HUD who changed the rules; it was Congress:
Section 202(f) of the National Housing Act mandates that all appraisers chosen or approved to conduct appraisals of properties that will be security for FHA-insured mortgages must: (1) be “certified” by the State in which the property to be appraised is located; or by a nationally recognized professional appraisal organization, and (2) have demonstrated verifiable education in the appraisal requirements established by FHA. (Note that the term “state” as used throughout this Mortgagee Letter includes U.S. Territories.)
HUD did not follow the mandate of Congress and immediately chuck the licensed overboard. They waited for a time and then stopped taking applications and renewal requests from licensed appraisers. Then they defied Congress by setting the effective date of October 1, 2009 before implementing the law enacted by Congress. HUD is actually the hero of the story giving licensed appraisers time to get certified.
HUD is not the meanie.. It is Congress that knows what it is doing as they usually do. Yeah Right!
Licensed appraisers are reacting differently. An appraiser friend who is about to retire is not doing anything. The appraiser in my office has taken courses and passed the exam and should be ready to face the Board in June. An ex-trainee of mine now on her own is taking courses and studying on-line to take the exam and probably will be ready to get certified in October.
Another young appraiser I know who got sick in 2007 is the worst off. He had a life threatening illness that prevented him from making the deadline in 2007 He has no college at all and is mostly doing FHA now. He will be severely hurt in October when he will be dropped on the list. I have advised him to seek a waive from the Board based on his illness and extenuating circumstances. I hope he follows up on my suggestion.
There is no easy answer but everyone has known since roughly October 2008 about the deadline October 2009. For those who want to stay on the panel, they were given a year to put their house in order. Dale Carnegie taught, " If it is meant to be, it is up to me."
Good luck to the great un-washed,
Doug