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NAR Response to GAO Questions

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larryhaskell

Senior Member
Joined
Apr 23, 2002
Professional Status
Certified General Appraiser
State
Nevada
Some of the responses sounded encouraging. I just have a hard time understanding and believing how these comments can come from the NAR based on some of my experiences with realtors in my area. I do like their position on the De minimus issue and AVMs.
 

George Hatch

Elite Member
Gold Supporting Member
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Jan 15, 2002
Professional Status
Certified General Appraiser
State
California
Frank,

As usual, NAR's response appears to be very well written and exhibits some pretty sound reasoning. Sound reasoning appeals to me a lot. I'd say I agree with at least 95% of it, which is more than I have in common with some of the "appraisal" organizations. As always, I really appreciate your efforts on our behalf. Thank you.


George Hatch
 

Francois K. Gregoire

Thread Starter
Senior Member
Joined
Jan 14, 2002
Professional Status
Certified Residential Appraiser
State
Florida
Frank,

As usual, NAR's response appears to be very well written and exhibits some pretty sound reasoning. Sound reasoning appeals to me a lot. I'd say I agree with at least 95% of it, which is more than I have in common with some of the "appraisal" organizations. As always, I really appreciate your efforts on our behalf. Thank you.


George Hatch

George,

Thanks for taking the time to read. Sure would appreciate it if you would take a little more time and offer suggestions. Here or by email would be fine.

Pleased to hear we are not that far apart, or, are moving towards a consensus.
 

George Hatch

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Gold Supporting Member
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Professional Status
Certified General Appraiser
State
California
Frank,

From an appraiser's point of view. there is little in NARs response to disagree with.

You may be interested in knowing, if you don't already know, that the Appraiser Qualifications Board of The Appraisal Foundation just sent out a memo today notifying USPAP instructors that the AQB has voted to rescind the examination requirement for the 7-hour National USPAP Update Course at this time. This, in response to the fact that some of the states would be unable to comply by the 01/2003 deadline.

So it would appear that the AQB and The Appraisal Foundation will respond to the legitimate interests of the state boards if enough reason and influence is brought to bear. Maybe if enough appraisers and other interested parties complain to the GAO, these legitimate complaints (ASC not doing enough, AQB/ASB/AF not responsive and conducting meetings in secret, etc) can be resolved fairly.

It doesn't matter to me who the agent of change is, whether it's Congress through the ASC as a result of the GAO findings, or the state boards setting a common standard as a group. The main prize to shoot for is a stable, fair and efficient system for appraiser regulation coupled with a similarly fair and efficient system for lender regulation.

When it comes to setting and enforcing appraisal standards and appraiser qualifications, none of the parties involved (the state boards as a group, the ASC, The Appraisal Foundation, and the lending community) can claim to be completely free of bias or politics. Each party is trying to protect their interests; the trick is how to reconcile these interests as best we can. I again assert that this is the only area where you and I have disagreed.


George Hatch
 
Joined
Jan 16, 2002
Professional Status
General Public
State
North Carolina
George and Frank

Thanks for the informative discussion and dialogue.

I read NAR's point paper and agree essentially with George.

My only observation is that on the issue of the debated on whether the discussions regarding policy is, or is to be, held by the ASC/AQB/ASB should be more public, I would add that state boards and AARO should be included in that list. If the regulators are of the belief that the Feds do not listen to them, they should be very receptive to hearing and implementing what appraisers are telling them.

I do not wish to belabor the Standard Three issue again, but look at how unresponsive Kentucky's Sam Blackburn comments on this forum were on this issue. He would not bother to explain the position because he considered it a waste of his time.

So I say, if we are going to make the debates public, lets do it at the state regulatory level as well.

Regards

Tom Hildebrandt GAA
 

Francois K. Gregoire

Thread Starter
Senior Member
Joined
Jan 14, 2002
Professional Status
Certified Residential Appraiser
State
Florida

So I say, if we are going to make the debates public, lets do it at the state regulatory level as well.


Tom,

Fully agree with you. But then, this is the procedure under which Florida conducts meetings. Any public board, conference or panel must meet 'In The Sunshine'. Any meeting must be noticed to the public, and with very few exceptions, open for the public to attend. Remember the 2000 Election, all the counting and meetings of the Canvassing Boards? Everything was out there in the open.

Board members cannot discuss ANY issue on which they may have to make a decision except in a properly noticed and convened public meeting. Two County Commissioners up the the panhandle were just convicted fof 'Sunshine Law' violations. Not sure of the penalties, but it weren't a pretty sight.

During meetings, you generally do not see the Florida Real Estate Appraisal Board whispering among themselves (once in a while a joke) or making comments to each other off microphone. All deliberations are right out there for the world to see. It may sometimes be uncomfortable for Board Members, but there sure are no secrets or hidden agendas. The comfort level of the Board is not as important as the public's right to know.
 
Joined
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Professional Status
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North Carolina
Frank

Your board actually has microphones and records its meetings?
This would be a heretical concept for the NCAB.

They routinely have "business dinners" at which they discuss policy but are which are not publically announced. They routinely send of policy statements and letters which are not publically discussed, and the communications are not noticed or published publically. They will give them to you if you ask for them specifically, but you must have specificity in the request.

The respondent is not even notified of the probable cause hearing in his case.

Yet the NCAB is crying loudly that the ASB and AQB do not have open meetings.

Perhaps florida does it well, but North Carolina is politics behind closed doors in spite of the laws.

Regards

Tom Hildebrandt GAA
 

Francois K. Gregoire

Thread Starter
Senior Member
Joined
Jan 14, 2002
Professional Status
Certified Residential Appraiser
State
Florida


Your board actually has microphones and records its meetings?
This would be a heretical concept for the NCAB.


Court Reporter too. Transcripts available!!

State Law
 
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