New Housing Bill/FHA Loans

[RSW]

Is it clear whether licensed appraisers on the roster will be grandfathered?

That's not part of the bill that was passed. It says you have to be certifed by the state.

 

[Greg Bell]

That's not part of the bill that was passed. It says you have to be certified by the state.

or certified by a National organization.You don't need an appraisal license at all.Read the "OR".....

 

[Doug Wegener]

read it again

That's not part of the bill that was passed. It says you have to be certifed by the state.

"Beginning on the date of enactment of the Federal 12
Housing Finance Regulatory Reform Act of 2008, 13
any appraiser chosen or approved to conduct ap- 14
praisals for mortgages under this title shall— 15"


It says any appraiser chosen or approved to conduct appraisal AFTER the date of enactment has to be certified by the State or else certified by an appraisal organization.

The way I read it, it is silent on those that were chosen or approved prior to the date of enactment.

If it said all licensed appraisers on the roster will be removed that would be clear, but it doesnt say that.

Did Congress intend all licensed appraisers to be removed from the panel? I dont know. As far as I can tell it was not discussed by Congress. I have tried to get both my Congressman and
one of my Senators to respond. They have not.

Bradd Pack said FHA didnt know whether they could continue to accept appraisals from licensed
appraisers. Their attorneys are studying the issue.

If its so clear, why didnt he know?

 

[RSW]

or certified by a National organization.You don't need an appraisal license at all.Read the "OR".....

Read my other posts first.

 

[RSW]

"Beginning on the date of enactment of the Federal 12
Housing Finance Regulatory Reform Act of 2008, 13
any appraiser chosen or approved to conduct ap- 14
praisals for mortgages under this title shall— 15"


It says any appraiser chosen or approved to conduct appraisal AFTER the date of enactment has to be certified by the State or else certified by an appraisal organization.

The way I read it, it is silent on those that were chosen or approved prior to the date of enactment.

If it said all licensed appraisers on the roster will be removed that would be clear, but it doesnt say that.

Did Congress intend all licensed appraisers to be removed from the panel? I dont know. As far as I can tell it was not discussed by Congress. I have tried to get both my Congressman and
one of my Senators to respond. They have not.

Bradd Pack said FHA didnt know whether they could continue to accept appraisals from licensed
appraisers. Their attorneys are studying the issue.

If its so clear, why didnt he know?

If it did not state they were to remain, then it would in my opinion mean they would be removed. That is not unclear to me at all.

 

[Common Sense]

I am with you RSW I don't think this is that hard to understand. then again I am just a Certified Appraiser what do I know.

:Eyecrazy::Eyecrazy::Eyecrazy:

 

[Doug Wegener]

Maybe

If it did not state they were to remain, then it would in my opinion mean they would be removed. That is not unclear to me at all.

Maybe so, but FHA doesnt seem to have clarity.

 

[Greg Bell]

I wouldn't worry about Licensing .Take look at what the field reviewers will be looking for in "YOUR" FHA reports.Click on one of the field review contracts and read "GENERAL REQUIREMENTS"...Yikes..
http://www.HUD.gov/offices/cpo/contract.cfm

 

[Doug Wegener]

Response from my Representative

Dear Congressman Issa:

I am writing about recently passed legislation, H.R. 3221, which you voted against. I am a California Licensed Appraiser in your District who is also currently on the FHA Panel.

One of the provisions of the new law is as follows:


SEC. 1404. REVISED STANDARDS FOR FHA APPRAISERS. 7
Section 202(e) of the National Housing Act (12 8
U.S.C. 1708(e)) is amended by adding at the end the fol- 9
lowing: 10
‘‘(5) ADDITIONAL APPRAISER STANDARDS.— 11
Beginning on the date of enactment of the Federal 12
Housing Finance Regulatory Reform Act of 2008, 13
any appraiser chosen or approved to conduct ap- 14
praisals for mortgages under this title shall— 15
‘‘(A) be certified— 16
‘‘(i) by the State in which the prop- 17
erty to be appraised is located; or 18
‘‘(ii) by a nationally recognized profes- 19
sional appraisal organization; and 20
‘‘(B) have demonstrated verifiable edu- 21
cation in the appraisal requirements established 22
by the Federal Housing Administration under 23
this subsection.’’.

The law as written is very unclear. In fact, my understanding is that HUD attorneys are currently studying it and do not know what it means. My questions are multiple.

1) Was the intention of Congress to remove all licensed appraisers on the current FHA roster or was it to have any newly approved appraisers after the date of enactment to be certified? Nobody, including HUD, seems to know whether currently licensed appraisers on the panel will be “grandfathered”

2) What did Congress mean by “Nationally recognized professional appraisal organization”. There are many national organizations. Which ones are included and which ones are not? Does it mean only those appraisal organizations that are members of the Appraisal Foundation? Or does it mean something else?

3) What did Congress mean by “Certified” by a National recognized professional organization? As far as I know, no appraisal orginaztion currently “certifies” their members. There are several that issue “Designations” to their members but not ‘Certifications”. Does the certification language actually mean designation?


As you can imagine, this is an issue of concern to me. Removing Licensed appraiser who have the experience and qualifications from the rooster will impact me and many others. Perhaps you can have a staff person research the answers to my questions and get back to me.

Thank You

Ted “Doug” Wegener
California Licensed Appraiser

****************

My Congressman never answered, but I sent the same letter to my Senator. Here is her response:





Dear Mr. Wegener:



Thank you for contacting me to express your concerns about legislation to regulate the home appraisal industry. I appreciate the time you took to write and welcome the opportunity to respond.



I am a cosponsor of the "Home Ownership Preservation and Protection Act of 2007" (S. 2452), introduced by Senator Christopher J. Dodd (D-CT) on December 12, 2007. As you know, this bill would require all appraisers to obtain a bond equal to one percent of the value of their annual home appraisals. It would also allow homeowners to collect on this bond in certain cases of appraiser error.



I understand your concern that the bonding requirement in Senator Dodd's bill may place a financial burden on small companies. Representative Brad Miller (D-NC) has introduced similar legislation to increase oversight and regulate the appraisal industry while not requiring appraiser bonding known as the "Mortgage Reform and Anti-Predatory Lending Act of 2007" (H.R. 3915). Please know that I will keep your thoughts in mind should either S. 2452 or H.R. 3915 come before the full Senate.



Once again, thank you for writing. If you have any additional questions or concerns, please do not hesitate to contact my Washington, D.C. office at (202) 224-3841. Best regards.




Sincerely yours,

Dianne Feinstein
United States Senator

************************

Not only can't they write a law that is clear but they cant even read their mail and understand what Im inquiring about.

 

[Couch Potato]

Get a response

Not only can't they write a law that is clear but they cant even read their mail and understand what Im inquiring about.

Now try contacting the opposing candidates for that house seat. Ask for their help and explain the incumbent's indifference to constituents. You might get a much better response, and maybe even some TV exposure for your plight. :new_all_coholic: