New Housing Bill/FHA Loans

[Mack McClain]

The new FHA requirements:

"Certified" means atleast Certified Residential level of license

or

Hold a nationally recognized professional appraisal designation and demonstrate verifiable education in FHA appraisal requirements

 

[Dennis]

The new FHA requirements:

"Certified" means atleast Certified Residential level of license

or

Hold a nationally recognized professional appraisal designation and demonstrate verifiable education in FHA appraisal requirements

I agree, they will now require a certified residential or general to be on the FHA roster. But, will those of us that are merely license be able to stay on the roster? I would think that once you are on, you are on! But we are talking about the government here...

It took more than a year for the state to upgrade me from a trainee. I should have taken the same USPAP class twice so I could go straight from trainee to certified, like most everyone else. That just seemed stupid to me to have to take a class twice, because the education hours have to be licensure hours, not just plain old CE hours. The only classes offered that are licensure level are the basic appraisal courses and USPAP.

Well, before the rules changed and the flood of apps hit I applied for a certified residential license in November. Then in JUNE of this year I get word for the board that they are missing a page of my refrences, and since its past 12-31-07, I now have to send in a new app with the new requirements.

I meet the new stuff, its just more time wasted to gather it all up, to have it lost after another eight months.

I'm seriously considering a move to the Florida panhandle!

 

[RSW]

As stated in a post before, the FHA can do what ever they want to. Back in the late 90's they made everyone take a 50 question test to remain on the roster. If you did not take the test and pass, then you were removed from the roster. If they want to remove all licensed appraisers, they can.

 

[Doug Meyer]

Brad, will FHA ever go back to the rotating fee panel? Has there been any discussion on this or is this a dead issue?

 

[Greg Bell]

HUD website still reads:

Eligibility requirements
Only appraisers who meet the eligibility criteria listed below may apply. An eligible appraiser must:

Be a state-licensed or state-certified appraiser with credentials based on the minimum licensing/certification criteria issued by the Appraiser Qualifications Board (AQB) of the Appraisal Foundation, and
Not be listed on the General Services Administration's Suspension and Debarment List, HUD's Limited Denial of Participation (LDP) List, or HUD's Credit Alert Interactive Voice Response System (CAIVRS).......

 

[Brad Pack]

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..

Greg-

I can't/won't comment on the "law" until the Department has conveyed its interpretation. Fortunately for me, whatever the interpretation, my job will not be affected.

 

[Brad Pack]

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.

My comments were admittedly/intentionally arrogant, but, they were factual. I was proving a point to some pompus "certified" appraisers. Actually, I do know one other appraiser with as well rounded FHA appraiser credentials. But he dealt more with policy issues [(HQ) plus outside experience] vs. my oversight/monitoring/enforcement experience (HOC). He is the one appraiser I go to for counsel (debate/argue with on a regular basis) other than my highly competent staff.

With all due respect, you don't have the first hand knowledge of whether or not the former FHA "test" was found to improve the roster's quality. I do.

I think you will find that you and I have more in common in regards to the "license vs. certified" issue than you think.

More to come...

 

[Brad Pack]

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.

I wouldn't "blindly choose" any appraiser. As a taxpayer who would you choose to do FHA appraisals, an MAI with commercial experience or me (a lowly licensed appraiser)?

 

[Couch Potato]

It will likely be at least a month before decisions are finalized and the web site is updated with new procedures.

Brad, I would choose the MAI whose office is one block from where I live over any appraiser from out of state.

 

[Brad Pack]

It will likely be at least a month before decisions are finalized and the web site is updated with new procedures.

Brad, I would choose the MAI whose office is one block from where I live over any appraiser from out of state.

Ahh, playing the ole geographic competency card, huh? Now that's funny!