New Housing Bill/FHA Loans

[RSW]

Brad Pack,

I have been certified for the last three years and was a licensed appraiser since 1993. I don't think that my being certified now makes me any more qualified to do an appraisal than when I was licensed. I have always tried to better myself with education and just did not feel the need to be certified for a long time. The only reason I got certified was I was thinking about taking on a trainee. So, I agree with you.

 

[timd354]

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.
I understand your frustration, but your comments are hardly factual.....they express your own opinion that you are the best or most qualified FHA appraiser on he face of the earth. This is your opinion, and an opinion that is quite arrogant and ane that you and some others may even believe to be true. However, it is hardly an objective fact.

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.
In that case, I am sure that you can provide the answer to that question along with where I can find the studies that back up your answer. In any case, if the former FHA test did not improve the roster's quality, the solution was not to eliminate the test and have no real standards to approve appraisers before adding them to the roster. The rather obvious solution to anyone, except apparently the people at the FHA, would have been to make the test much more comprehensive and difficult in order to weed out incompetent appraisers.

I think you will find that you and I have more in common in regards to the "license vs. certified" issue than you think.
I am in agreement with you that the metric of "licensed vs. certified" is not very useful to determine who is actually qualified to do FHA appraisals.
More to come...

Unfortunately, the Congress has apparently decided to make the "licensed vs. certified" metric the benchmark to do FHA appraisals. The langauage of the statute is very clear and does not appear to allow existing FHA roster appraisers who do not meet the new standards to be "grandfathered" in.....but we will just have to see what the HUD/FHA attorneys come up with and then have to wait and see if the new rules survive any judicial challenges.

Since I am a state certified appraiser, I have no dog in this fight, but I do not wish to see any competent and ethical appraisers removed from the panel. I am interested, however, in seeing that all incompetent appraisers get removed from the panel ASAP and that more incompetent appraisers are not added to the panel. It is my opinion that the FHA has failed miserably in this regard.

 

[timd354]

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.

So you are saying that if the new law is interpreted to mean that you are unable to perform FHA appraisals since you are not state certified that you will be allowed to continue to be the Chief Appraiser for the Santa Ana HOC?

I highly doubt it.....you may well remain in some job at the FHA, but if it is determined that you are not legally qualified to be an FHA appraiser under the new law, then you could hardly remain the Chief Appraiser for an HOC.

That being said, I think that the new statute is idiotic in that respect and that outcome, while possible because of the langauge of the statute, is not an outcome that I would like to see.

 

[Couch Potato]

Not very clear.

Unfortunately, the Congress has apparently decided to make the "licensed vs. certified" metric the benchmark to do FHA appraisals. The langauage of the statute is very clear and does not appear to allow existing FHA roster appraisers who do not meet the new standards to be "grandfathered" in.....but we will just have to see what the HUD/FHA attorneys come up with and then have to wait and see if the new rules survive any judicial challenges.

That is easily a debatable issue. The new law says, "any appraiser chosen or approved" which can mean different things. Are those already on the roster already chosen and approved? Does renewal count as being chosen and approved? Does chosen and approved apply to each individual assignment? Would the FHA be better served politically to just use certified appraisers?

Then there is the question of how individual clients react. If the clients know licensed appraisers could not be added to the roster now, do they avoid using them to protect their image with their customers? Right or wrong there is a potential of this law to lower the perception of the Licensed level among appraisal clients.

 

[Greg Bell]

That is easily a debatable issue. The new law says, "any appraiser chosen or approved" which can mean different things. Are those already on the roster already chosen and approved? Does renewal count as being chosen and approved? Does chosen and approved apply to each individual assignment? Would the FHA be better served politically to just use certified appraisers?

Then there is the question of how individual clients react. If the clients know licensed appraisers could not be added to the roster now, do they avoid using them to protect their image with their customers? Right or wrong there is a potential of this law to lower the perception of the Licensed level among appraisal clients.

Licensed appraisers certainly have a lowered perception on this forum , however , in the real world lenders don't give a hoot about Licensed versus Certified.They just want the job done by a qualified appraiser.Most of them don't even know the difference , which is none save a million dollar property .
Maybe after 10 or so years of Licensing you could just take a test and poof , instant Certified.FHA probably doesn't really know the difference between the two classifications.There seems to be a weasel clause in "National Organization" certification , whatever that is.So if FHA will only allow State Certified appraisers to appraise FHA then it would stand to reason that any Licensed appraiser may obtain an FHA certification to continue appraising.The term "or" is very powerful word in the legal mumbo jumbo world.Anyway , we can always sue ,it's the great American pasttime...

 

[Couch Potato]

Things change.

Licensed appraisers certainly have a lowered perception on this forum , however , in the real world lenders don't give a hoot about Licensed versus Certified.

......

Anyway , we can always sue ,it's the great American pasttime...

In the real world things change quickly. I remember two appraisers in my G1 class back in 2003 (last class to qualify for Certified Residential at that time.) They were working under trainee licenses, and had been for more than ten years. They liked the lower liability and having supervision. Clients liked there work and they never had trouble getting it accepted. Suddenly that all changed and lenders would no longer accept their work. A banking regulation was reworded in a way that most lenders interpreted as requiring a Licensed or Certified appraiser do the appraisal rather than just reviewing and approving the work of a trainee. They jumped through the hoops for Certification and kept on working. Legally there was no reason they could not still do the work as trainees, but market perception dictated otherwise.

Likewise, as the minimum standard to get approved changes, client requirements could change to match even if the Licensed level is deemed acceptable by FHA for those already on the roster. I think you are wrong about, "Licensed appraisers certainly have a lowered perception on this forum." Pointing out things like the $250,000 transaction limit for complex properties applying to a situation is not a reflection on the appraiser or their abilities, but a reflection on the legal realities of a situation. All too often such comments are taken inappropriately as a question of competency rather than legal license scope. The FHA situation is similar. It is not about competency, but legal license scope.

 

[Greg Bell]

Strange rule would be for Certified only appraisers and no test for FHA competence(Which I took in 2000).Licensed limitations in this state hardly make a dent.Looks like us poor maligned Licensed appraisers will need a temporary weasel clause and will be forced to upgrade for future FHA appriasals....or , they could toss the whole clause Right out , who knows , stay tuned.

 

[Brad Pack]

So you are saying that if the new law is interpreted to mean that you are unable to perform FHA appraisals since you are not state certified that you will be allowed to continue to be the Chief Appraiser for the Santa Ana HOC?

I highly doubt it.....you may well remain in some job at the FHA, but if it is determined that you are not legally qualified to be an FHA appraiser under the new law, then you could hardly remain the Chief Appraiser for an HOC.

That being said, I think that the new statute is idiotic in that respect and that outcome, while possible because of the langauge of the statute, is not an outcome that I would like to see.

FHA staff appraisers do not perform appraisals.

 

[Greg Bell]

FHA staff appraisers do not perform appraisals.

I see big changes in HUD to comply with the new legislation.It will be interesting to see them play out.Have you been there since HUD was on Broadway St. in LA ?..That was a long time ago , ah , the good ole days...

 

[Brad Pack]

Unfortunately, the Congress has apparently decided to make the "licensed vs. certified" metric the benchmark to do FHA appraisals. The langauage of the statute is very clear and does not appear to allow existing FHA roster appraisers who do not meet the new standards to be "grandfathered" in.....but we will just have to see what the HUD/FHA attorneys come up with and then have to wait and see if the new rules survive any judicial challenges.

Since I am a state certified appraiser, I have no dog in this fight, but I do not wish to see any competent and ethical appraisers removed from the panel. I am interested, however, in seeing that all incompetent appraisers get removed from the panel ASAP and that more incompetent appraisers are not added to the panel. It is my opinion that the FHA has failed miserably in this regard.

Trust me, every "certified" appraiser has a dog in this fight. A mere state "certification" could easlily become the next target of the self-serving elitists in this industry, who routinely exercise political manipulation.