New Housing Bill/FHA Loans

[timd354]

I submit this post as a private citizen/taxpayer/LICENSED APPRAISER. The following views/opinions are mine alone, and not that of the Department.

When licensing first started 92/93 a license level required 75 hours of basic education, certified residential 105 hours, general certified 120 hours. I had 115 hours. Unfortunately, a couple of my classes were done via correspondence (final test with proctor). During that time correspondence classes were not acceptable for the certified levels. This rule subsequently changed to allow correspondence courses for certified levels. So, here I sit a mere licensed appraiser. It seems some of you believe this alone makes me unqualified to complete FHA appraisals.
It seems like Congress, in a typical demonstration of Congressional stupidity, may have decided that you are unqualified to do FHA appraisals...unless you and others find a loophole in the law, such as perhaps getting "certified" by a "nationally recognized professional appraisal orgainization". The statutatory language does not contain any provision that would seem to allow the FHA to "grandfather" in approved FHA appraisers who do not meet the new standards....it will be interesting to see if the FHA can or will try to grandfather in these people through the promulgation of new regulations, and, if they do, whether or not such regulations will survive judicial scrutiny.

I submit my credentials/qualifications:

Appraiser for 19 years (13 years independent fee appraiser/6 years HUD/FHA staff).
Former FHA Fee Panel Appraiser (CHUMS# 2353)
Former FHA Roster Appraiser
Former FHA Review Appraiser (sub-contractor)
Former FHA Review Appraiser (contractor)
Former FHA Senior Review Appraiser, (Staff) HUD/FHA Santa Ana Homeownership Center
Currently FHA Chief Appraiser, (Staff) HUD/FHA Santa Ana Homeownership Center
Have performed and supervised numerous forensic appraisal reviews for the Office of Inspector General for major criminal investigations
Have performed thousands of FHA appraisals
Have performed thousands of FHA appraisal reviews (administrative and technical)
Regularly assist HUD Headquarters on appraisal policy issues
Regularly review staff and contractor appraisal reviews and recommend varying degrees of sanction to be imposed on FHA roster appraisers.

Those are impressive credentials to be sure.

Pardon me sir, but, what are your credentials? 15 years and a state certification? FACT:
Your credentials are not even remotely close to mine. I've forgotten more about FHA appraisal than you and every poster in this forum combined, will ever know. I could make a career out of correcting the answers I read in this forum. There is no appraiser in this country that has the FHA appraisal credentials I have. I defy Mel Martinez, any politician, any person, the ASB, AQB, AI, NAIFA, ASA etc. to produce a designated or "certified" appraiser more competent than I to develop and report an FHA appraisal.
Now that is quite an assertion...it is the most arrogant statement that I have ever seen posted on this forum, and that is saying a lot!!!......In any case, unless you are grandfathered in or become "certified" as defined in the new statute, then every "certified" appraiser on the FHA appraisers panel will be more competent than you to develop and report an FHA appraisal, since by operation of law, you will no longer have any competence to legally develop and report an FHA appraisal.
Now, is everyone done being arrogant and rude here? Because, I am.

I will submit positive and constructive commentary about this issue in the near future. I hope you all will do the same. Let us move on.

The new law is what it is and time will tell how it is interpreted by the HUD/FHA lawyers and the courts....we are all just going to have to wait to see how this all plays out.

The last thing that I will say about this matter is that it is my opinion that the FHA may well have caused this result when it stupidly (in my opinion) did away with the testing requirements for appriasers to be added to the FHA approved appraisers panel. Perhaps Congress felt compelled to act becuase it sure appeared to many people that the FHA had absolutely no standards for approving FHA eligible appraisers except that they needed to be licensed and have a pulse. I am sure that this comment will annoy you to no end Brad, but that is just the way that I see things.

In any case, I hope that the FHA comes up with some method that is compliant with the new statute that will allow competent appraisers who are currently on the panel to remain on the panel while at the same time eliminates the many incompetent and unethical appraisers who are currently on the panel.

 

[Greg Bell]

Right on Brad....Licensed 16 years for me including numerous HUD Field review contracts and 10 years HUD REO appraiser.I still do not know if you or me will be able to continue appraising FHA as of Oct 1 .Poorly written verbage can kill..

 

[Don Clark]

The new law is what it is and time will tell how it is interpreted by the HUD/FHA lawyers and the courts....we are all just going to have to wait to see how this all plays out.

The last thing that I will say about this matter is that it is my opinion that the FHA may well have caused this result when it stupidly (in my opinion) did away with the testing requirements for appriasers to be added to the FHA approved appraisers panel. Perhaps Congress felt compelled to act becuase it sure appeared to many people that the FHA had absolutely no standards for approving FHA eligible appraisers except that they needed to be licensed and have a pulse. I am sure that this comment will annoy you to no end Brad, but that is just the way that I see things.

In any case, I hope that the FHA comes up with some method that is compliant with the new statute that will competent appraisers who are currently on the panel to remain on the panel while at the same time eliminates the many incompetent and unethical appraisers who are currently on the panel.

Well said. I certainly do not doubt Brad's qualifications and that of many of the Licensed Appraisers who have been posters on this and other forums such as the AI and the NAIFA Forums for many years. I feel better knowing that there are folks like Brad that work for the FHA. We need more just like him at every HOC.

FHA will never go back to a Fee Panel. But, it would certainly lend credibility to the current roster if all of us that are currently on the roster would have to take a comprehansive written exam that is at least as difficult as the current 2008 exam for the Certified Residential level but based on FHA requirements.

It is obvious to me that many posters, whether the are Certified or Licensed, on this forum, have no clue on what is required in an FHA appraisal. Many do not even have a copy of the 4150.2 although one can easily be downlodade from the HUD website or obtained free of charge from the Government printing Office. Even more have never read the new protocol, and have no idea how to find it. Even more have never seen a VC sheet and understand that most of the requirements on that VC sheet are still required for an FHA appraisal.

Certification is not the answer. Education about FHA Requirements and competence are. That is the advice that I hope Brad gives to the FHA.

For those who do not know where to get the information I suggested:

http://www.HUD.gov/offices/adm/hudclips/letters/mortgagee/2005ml.cfm

 

[Couch Potato]

Nothing Personal.

I've forgotten more about FHA appraisal than you and every poster in this forum combined, will ever know. I could make a career out of correcting the answers I read in this forum. There is no appraiser in this country that has the FHA appraisal credentials I have. I defy Mel Martinez, any politician, any person, the ASB, AQB, AI, NAIFA, ASA etc. to produce a designated or "certified" appraiser more competent than I to develop and report an FHA appraisal.

Now, is everyone done being arrogant and rude here? Because, I am.

I will submit positive and constructive commentary about this issue in the near future. I hope you all will do the same. Let us move on.

Sorry to hear your mind is going.
(Just a joke. My standard comment after you post is, "do what Brad said.")

There are certainly many highly qualified Licensed appraisers. However, looking at the most qualified is not the way to evaluate the law. The place to look is the least qualified of a given license level. Up until a couple years ago a high school drop out could slap together 5 reports a day for 2 months and be licensed in North Carolina. That's right. Grand total of 2 months "experience" and out on their own. (Possibly with a trainee under them!) When people started do just that, NC put a minimum year standard out there, but they could still be a high school drop out. (Today the Licensed level is not even available and one needs a high school diploma or GED just to be a Trainee.) So it is entirely possible for a Licensed appraiser in NC to have one year of experience being trained by someone who had two months experience under someone else with two months experience. Does anyone have a problem with not letting such an individual do FHA work?

On the other hand, being Certified has required a minimum of two years experience under another Certified appraiser. Although it is entirely possible the Certified appraiser is an idiot, if you had to blindly chose one over the other would you not want the Certified appraiser doing your appraisal?

Mel Martinez just did a good job representing the position of his state government as senators are supposed to do. It has been more than 5 years since Florida stopped issuing the Licensed level. It is nothing personal. No one is claiming there are not highly qualified Licensed appraisers. I believe the assumption is a highly qualified Licensed appraiser will have little trouble becoming Certified. On the other hand the minimally trained and minimally qualified Licensed appraiser will struggle (or be unable) to be Certified.

 

[timd354]

Sorry to hear your mind is going.
(Just a joke. My standard comment after you post is, "do what Brad said.")

There are certainly many highly qualified Licensed appraisers. However, looking at the most qualified is not the way to evaluate the law. The place to look is the least qualified of a given license level. Up until a couple years ago a high school drop out could slap together 5 reports a day for 2 months and be licensed in North Carolina. That's right. Grand total of 2 months "experience" and out on their own. (Possibly with a trainee under them!) When people started do just that, NC put a minimum year standard out there, but they could still be a high school drop out. (Today the Licensed level is not even available and one needs a high school diploma or GED just to be a Trainee.) So it is entirely possible for a Licensed appraiser in NC to have one year of experience being trained by someone who had two months experience under someone else with two months experience. Does anyone have a problem with not letting such an individual do FHA work?

On the other hand, being Certified has required a minimum of two years experience under another Certified appraiser. Although it is entirely possible the Certified appraiser is an idiot, if you had to blindly chose one over the other would you not want the Certified appraiser doing your appraisal?

The Couch Spud is exactly correct in his analysis. It is kind of ironic that Brad Pack may get caught up in this new law after the way that he ripped me for having the temerity to harshly criticize the FHA for having virtually no standards for adding appraisers to the FHA approved appraisers panel....It is very interesting to look at our prior exchanges on this subject starting with post #11 on this thread:
http://appraisersforum.com/showthread.php?p=1633728#post1633728

That being said, it is obvious that Brad is very knowledgeable and an undoubtedly does very good work for the FHA...thus, I hope that the FHA can come up with a solution that allows existing competent FHA approved appraisers remain on the approved appraisers panel while at the same time eliminating the incompetent appraisers.

 

[TJSum]

How about this idea to comply with the legislation which would be the easiest way for FHA/HUD to adapt to the policy.

The FHA current roster of appraisers could be considered a "national appraisal organization as a group". FHA/HUD could develop a class for each appraiser to take and/or bring back the 100 question test that many of us had to pass. Once an appraiser passes the "requirements" set by HUD, they would then become "certified" FHA panel appraisers qualified to do FHA work.

It would be open to all License levels, it would meet the certified requirement and also the requirement of proving each appraiser has the qualifications and education to proceed with FHA work.

 

[timd354]

How about this idea to comply with the legislation which would be the easiest way for FHA/HUD to adapt to the policy.

The FHA current roster of appraisers could be considered a "national appraisal organization as a group". FHA/HUD could develop a class for each appraiser to take and/or bring back the 100 question test that many of us had to pass. Once an appraiser passes the "requirements" set by HUD, they would then become "certified" FHA panel appraisers qualified to do FHA work.

It would be open to all License levels, it would meet the certified requirement and also the requirement of proving each appraiser has the qualifications and education to proceed with FHA work.

Interesting possible solution....but I believe it is a real stretch to say that the FHA would fall within the definition of "nationally recognized professional appraisal organization" The FHA is a government entity, not a professional appraisal organization under any fair reading of the meaning of those terms. Now, would it be possible for the FHA to set up or sponsor such an organization....maybe, maybe not...I have no idea if the FHA would legally be authorized to that or not.

 

[Don Clark]

Interesting possible solution....but I believe it is a real stretch to say that the FHA would fall within the definition of "nationally recognized professional appraisal organization" The FHA is a government entity, not a professional appraisal organization under any fair reading of the meaning of those terms. Now, would it be possible for the FHA to set up or sponsor such an organization....maybe, maybe not...I have no idea if the FHA would legally be authorized to that or not.

Don't think so. Appraisal organizations are private, usually non profit. A Government agency would not or could not be a membership organization.

 

[Doug Wegener]

Relief

I submit this post as a private citizen/taxpayer/LICENSED APPRAISER. The following views/opinions are mine alone, and not that of the Department.

When licensing first started 92/93 a license level required 75 hours of basic education, certified residential 105 hours, general certified 120 hours. I had 115 hours. Unfortunately, a couple of my classes were done via correspondence (final test with proctor). During that time correspondence classes were not acceptable for the certified levels. This rule subsequently changed to allow correspondence courses for certified levels. So, here I sit a mere licensed appraiser. It seems some of you believe this alone makes me unqualified to complete FHA appraisals.

I submit my credentials/qualifications:

Appraiser for 19 years (13 years independent fee appraiser/6 years HUD/FHA staff).
Former FHA Fee Panel Appraiser (CHUMS# 2353)
Former FHA Roster Appraiser
Former FHA Review Appraiser (sub-contractor)
Former FHA Review Appraiser (contractor)
Former FHA Senior Review Appraiser, (Staff) HUD/FHA Santa Ana Homeownership Center
Currently FHA Chief Appraiser, (Staff) HUD/FHA Santa Ana Homeownership Center
Have performed and supervised numerous forensic appraisal reviews for the Office of Inspector General for major criminal investigations
Have performed thousands of FHA appraisals
Have performed thousands of FHA appraisal reviews (administrative and technical)
Regularly assist HUD Headquarters with appraisal policy issues
Regularly review staff and contractor appraisal reviews and recommend varying degrees of sanction to be imposed on FHA roster appraisers.



Pardon me sir, but, what are your credentials? 15 years and a state certification? FACT:
Your credentials are not even remotely close to mine. I've forgotten more about FHA appraisal than you and every poster in this forum combined, will ever know. I could make a career out of correcting the answers I read in this forum. There is no appraiser in this country that has the FHA appraisal credentials I have. I defy Mel Martinez, any politician, any person, the ASB, AQB, AI, NAIFA, ASA etc. to produce a designated or "certified" appraiser more competent than I to develop and report an FHA appraisal.

Now, is everyone done being arrogant and rude here? Because, I am.

I will submit positive and constructive commentary about this issue in the near future. I hope you all will do the same. Let us move on.

Personally, Im glad there is an FHA Chief appraiser who is "merely" Licensed. Maybe with his input FHA and Congress can remedy the situation so licensed appraisers who are qualified can continue to do FHA work. Anything less seems an injustice.

 

[rcsone]

......Mr. Pack thanks for the postings of quality or the quality of poster.......opinions are like most clutter, when shared-------difficult to ignore and frequent in accumulations....best to all...rs