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Doug Wegener

Senior Member
Joined
Apr 14, 2005
Professional Status
Certified Residential Appraiser
State
Oregon
You knew a poll on this issue was coming.

Does the new FHA Bill eliminate Licensed Appraisers from the FHA panel?
 
My guess would be that it may stop future L holders from joining. Very rarely does the gov't change rules without grandfathering in the current stable.

Great poll.

Of course, it is flawed, as there is no poll.
 
That was just to get you excited.Poll in another post.
 
I am not sure tht the authors of the bill knew the difference between licensed and certified and intended that an appraiser just be recognized by the state. I am fairly sure that is where things will end up. I think that the FHA will be able to interpret that word as they choose. I doubt they will seek to slash the roster at a time when FHA loans are going to greatly grow in number.

FHA limits are well below the licensing limits. Unless FHA has some damning statistics about sanctions against a higher number of licened versus certified, there would be no reason to do this.

If it stands, it appears to be another effort by the industry to pull the ladder up behind them, and another membership drive by the AI. Since the AI does not certify anyone, there is another flaw in the language.

Extended time in grade does not seem to produce better reports. It still comes down to personal ethics much more than professional competence.
 
I have not once seen the word certified in capital letters, which would then infer a Certified Appraiser.

I think the bill uses the term certified to refer to those with licenses. The definition of certified is many:

endorsed authoritatively as having met certain requirements; "a certified public accountant"
certifiable: fit to be certified as insane (and treated accordingly)
holding appropriate documentation and officially on record as qualified to perform a specified function or practice a specified skill; "a registered pharmacist"; "a registered hospital"

and

Acknowledging that a product is genuine to what it claims, typically having gone through a process similar to obtaining a license.

and

Recognized by a professional association or professional regulatory organization as possessing the appropriate combination of credentials ...

and

Licensed or qualified.

Definitions obtained from

http://www.google.com/search?hl=en&...ertified&sa=X&oi=glossary_definition&ct=title

and from http://www.thefreedictionary.com/certified

cer·ti·fy (sûrt-f)
v. cer·ti·fied, cer·ti·fy·ing, cer·ti·fies
v.tr.
1.
a. To confirm formally as true, accurate, or genuine.
b. To guarantee as meeting a standard: butter that was certified Grade A. See Synonyms at approve.
2. To acknowledge in writing on the face of (a check) that the signature of the maker is genuine and that there are sufficient funds on deposit for its payment.
3. To issue a license or certificate to.
4. To declare to be in need of psychiatric treatment or confinement.
5. Archaic To inform positively; assure.
 
Will likely end up depending on whether or not your state continues to allow the "licensed" level. That level is no longer issued here in NC, and the NCAB has grandfathered Licensees for some time, maybe indefinitely, but you cannot apply for or become "Licensed" in NC anymore. I think out of the 4000+/- appraisers here, there were only about 200 at the License level at last count. I said I think, my numbers are subject to slight correction. :)

If enough states are going to continue to allow Licensees to operate in a fashion similar to that of most Certs, with a few monetary and complexity limitations as in the past, then FHA will likely still allow Licensees on their panel. The state of NC wants Licensees to move up or move on (out of the business) though - can't say how many there'll still be here in a year or two from now.
 
I'm not sure what will happen, it depends on how FHA interprets the provision. The language is clear in the statute that FHA appraisals must be done by someone who is certified in the state that the property is located or by someone who is certified by a nationally recognized appraisal organization (NRAO)

The first part is pretty simple. If you are certified you have no issue here. The second part is very vague. If you are licensed I suppose you will have to be certified by a NRAO. But they did not define what that is. One would think that a member of the Appraisal Foundation would fit the bill for this, but I don't know of any that offer a certification (they offer designations of course). This part of the statute was very poorly written. I think the AI and a few others intended for this to say designated but it did not come out that way.

We will have to wait for the FHA lawyers to figure this out. I think everyone should keep in mind that this is a congressional directive to FHA. I can't imagine FHA taking anyone off the panel without cause. It simply would not be fair, but it may happen.

By the way, the requirement that someone join a private organization in order to do g'ment work has some constitutional issues.
 
You knew a poll on this issue was coming.

Does the new FHA Bill eliminate Licensed Appraisers from the FHA panel?

I guess I missed the poll part.

Answer: NO

I dont think the lawmakers knew what they meant when they wrote the law. Furthermore, Licensed appraisers would scream like mashed cats.

The Licensed level license category was created for two reasons: (1) to appease the whiners who couldn't make it to Certified and (2) to insure there would never be a shortage of appraisers by setting the standards so low that anyone with an ounce of determination could become an appraiser.

On top of that the regulators raised the de minimus level to the current 1 million to make everybody happy.

If you weren't around in '89 when all this started spare me your comments because I WAS there and I heard the great debates. I know exactly why the Licensed category was created.

Unfortunately, this vocation is going to have to set up some sort of grandfathering to get rid of the Licensed appraisers. I suggest letting them slide on the AA/21-hours, but requiring them to meet the remaining requirements for Certification within 3 years - a date CERTAIN - or hit the road. I don't care how long some of them have been in business.

The real issue is incoming appraisers, new Licensed appraisers dead set on getting out from under supervision ASAP and anxious as hell to suck up to the AMCs. NO appraiser is qualified to appraise real estate unsupervised after "no less than 12 months" experience and frankly, 24 months isn't enough either.

If this vocation ever intends to gain back our self-respect we need to get rid of the one-year wonders and start focusing on supply and demand issues. The AQB has given us new reasonable standards, finally; let's not allow the Licensed level appraisal category to continute to circumvent those new guidelines. Certification is the new minimum.

BTW, I'm all for EVERY Certified appraiser nationwide being required to pass the new national uniform exam within 3 years or they get the boot too. I don't want to hear them whine either. If you've been practicing in this business for 2-3-4-5 years, you're Licensed or Certified and you're too freaking stupid to pass an appraisal exam then IMO you don't deserve to be in the business.
 
Is it that tough to become certified? Easiest test I ever took.


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