New Poll

[Michigan CG]

Maybe some state appraisal boards will recognize the damage created by the whole comp check process, label them illegal, and begin a random calling campaign, like random drug checking...........

PLEASE, PLEASE...I would kill small farm animals for that type of action. It is a disease that is a big contributor to this current mess. $1,000 fines for those giving a comp check and $1,000 fines for those asking for one. It is already illegal in Michigan to give an oral report, good state to start with.

 

[Mr Rex]

Tim, I think Oregon or NC may be first to do this. I plan on making a short trip to 2 NCAB members offices ( 1 in my town, 1 in the next town over) to express my opinion in person. Oregon's board has been the most pro-active IMO, but NC has stepped up on draft appraisals etc. Of course they don't do nearly enough for BI/USPAP Compliant, but his thorn surely makes their side sore enough to do the right thing in many cases, but we have a long way to go, and must take the road not taken (per Frost)

 

[RSW]

Rex, that's a great idea. I think I'll contact our commissioners and put a bug in their ear too.

 

[Doug Wegener]

Nope

It may not be fair, but here is what I think will happen. FHA will send out a letter reading pretty much like this:

"Effective 10/1/2008 all FHA appraisals must be completed by an appraiser who is certified by the state in which the subject property is located. The FHA roster will be updated and will show as active only state certified appraisers who passed either the 100 question exam administered by Sylvan or the 10 question internet exam. Appraisers currently on the list who do not meet these qualifications will not be removed from the roster but their status will be "inactive". We expect to have a new test ready soon, perhaps by 2011.

We are doing this in order to comply with the congressional directive in the recently passed housing bill. While the bill gives FHA the option to use appraisers who have been certified by a nationally recognized appraisal organization or NRAO, we have come to the conclusion that this option is too cumbersome to implement at this time. We are real busy right now implementing a very complicated mandate from congress, and we just don't have time to slice and dice what constitutes a NRAO. We also don't want to be hauled up in front of the Senate banking committee and explain why we recognize as a NRAO some outfit that certified Tobias The Cat.

Our lawyers have also informed us that requiring FHA appraisers to become members of a private organization may be unconstitutional".

I personally don't think it's fair but I do think that something similar to this will happen.

"We are real busy right now implementing a very complicated mandate from congress, and we just don't have time to slice and dice what constitutes a NRAO."

Nope. Wouldnt stand up in courts. FHA doesnt have the option of ignoring what Congress says.

 

[Greg Bell]

I agree.If they uphold the "Certified "clause then the must uphold the "National Organization" clause.Who wrote this baloney.

 

[Bama Bayou]

"We are real busy right now implementing a very complicated mandate from congress, and we just don't have time to slice and dice what constitutes a NRAO."

Nope. Wouldnt stand up in courts. FHA doesnt have the option of ignoring what Congress says.

Your right, they don't have the option of ignoring congress. However, the statute gives them the option of using a state certified appraiser or a NRAO certifed and no one know what that means.

I bet they go with the first option. Maybe not. I don't think it's fair to take people off the roster without cause, but it may happen.