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Operation Reverse Pressure

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jeff samolinski

Senior Member
Joined
Apr 18, 2003
To be sent to all relevant agencies involved in the real estate profession:

I AM TYPING IN CAPS CAUSE I THINK ITS EASIER TO READ.
ALSO I KNOW THAT I DO NOT REPRESENT THE FORUM. JUST TRYING TO GET SOMETHING DOWN IN WRITING THAT WE CAN BRING TO PEOPLE ON THE FORUM FOR DISCUSSION/APPROVAL BEFORE WE EVEN SAY WE REMOTELY REPRESENT ANYONE SO DON'T GET INTO A HISSY YET!

WE ARE APPRAISERS THAT ARE PART OF A LARGER GROUP OF APPRAISERS AND OTHERS THAT COMMUNICATE WITH EACH OTHER VIA A WEBSITE CALLED "THE APPRAISERS FORUM". THERE ARE APPROXIMATELY ? NUMBER OF APPRAISERS, REALTORS, LENDERS AND OTHERS INVOLVED IN THE REAL ESTATE PROFESSION THAT COMMUNICATE WITH EACH OTHER VIA THE FORUM. OF THOSE THERE ARE APPROXIMATELY ? THAT ARE ACTIVE IN THE FLORIDA SECTION OF THE APPRAISERS FORUM.

THROUGH THIS FORUM WE HAVE COME TO THE REALIZATION THAT THERE IS A CRITICAL NEED FOR ALL THOSE INVOLVED IN THE SALE, FINANCING AND APPRAISAL OF REAL PROPERTY TO MEET TOGETHER ALL AT ONCE IN ONE PLACE FOR THE PURPOSE OF FUTHERING OUR UNDERSTANDING OF EACH OTHERS' ABILITY TO WORK TOGETHER FOR THE BETTERMENT OF THE PUBLIC.

IT IS OUR BELIEF THAT BECAUSE THE REAL ESTATE PROFESSION INVOLVES SEVERAL DIFFERENT TYPES OF PROFESSIONALS COMING FROM SEVERAL DIFFERENT PERSPECTIVES AND THAT THESE DIFFERENT PERSPECTIVES CREATE A VARIETY OF PROBLEMS BETWEEN THESE PROFESSIONALS WHICH CAN ONLY BE SOLVED VIA AN INTER-AGENCY PROCESS. EACH OF THESE PROFESSIONALS ARE REGULATED BY DIFFERENT AGENCIES THAT HAVE DIFFERENT SETS OF RULES AND ETHICS. THE PROBLEMS THAT EXIST BETWEEN THESE INTER-RELATED PARTIES CAN ONLY BE SOLVED BY SOME TYPE OF INTER-AGENCY MEETING PROCESS BECAUSE NO ONE REGULATORY AGENCY HAS THE AUTHORITY IN AND OF ITSELF TO DEAL WITH THESE INTER-RELATED PROBLEMS.

WE COME BEFORE THE FLORIDA REAL ESTATE APPRAISAL BOARD FIRST WITH OUR REQUEST BECAUSE THE APPRAISERS FORUM HAS THE HIGHEST REGARD FOR THE BOARD'S PAST ACCOMPLISHMENTS AND IT IS KNOWN TO BE THE MOST PROGRESSIVE BOARD ACROSS THE COUNTRY. WE HAVE CONFIDENCE THAT THIS BOARD WILL CONSIDER OUR REQUEST AND AGREE WITH THE MERITS OF OUR RECOMMENDATION. WE FULLY UNDERSTAND THAT THE BOARD DOES NOT HAVE THE AUTHORITY TO DEAL WITH ALL OF THE ISSUES TO BE RAISED IN THIS REQUEST AND WE ARE AWARE OF THE FULL AGENDA THAT THE BOARD ALREADY HAS. HOWEVER, IT IS OUR BELIEF THAT THE OUTCOME OF OUR SUGGESTION HAS A VERY GOOD CHANCE OF REDUCING THE BOARD'S FUTURE WORK LOAD PARTICULARLY IN THE AREA OF HAVING TO DISCIPLINE APPRAISERS.

WE RESPECTFULLY REQUEST THAT THE BOARD TAKE THE LEAD IN CALLING FOR AN INTER-AGENCY CONFERENCE OF THE FOLLOWING PROFESSIONALS AND THE BOARDS THAT REGULATE THEM--REALTORS, MORTGAGE BROKERS, LENDERS OF ALL TYPES, FNMA, FREDDIE MAC, APPRAISERS AND MEMBERS OF THE GENERAL PUBLIC AS THE ULTIMATE USERS OF THE ENTIRE PROCESS. ALTHOUGH IT WOULD BE IDEAL FOR THESE DIFFERENT AGENCIES TO MEET TOGETHER AS A MATTER OF MUTUAL CONSENT WE BELIEVE THAT THE ISSUES ARE OF SIGNIFICANT IMPORTANCE FOR THE BOARD TO CONSIDER INVOKING ITS AUTHORITY TO REQUEST A MEETING BETWEEN THESE VARIOUS BOARDS PURSUANT TO FLORIDA STATUTES 455.207(5) AND FLORIDA STATUTES 475.614 SPECIFICALLY "THE BOARD MAY DECIDE QUESTION SOF PRACTICE ARISING IN THE PROCEEDINGS BEFORE IT, HAVING REGARD TO THIS SECTION AND THE RULES THAN IN FORCE." IN ADDITION, PURSUANT TO F.S. 475.613(2), WHEREBY THE BOARD IS AUTHORIZED TO ESTABLISH STANDARDS FOR REAL ESTATE APPRAISALS.

SPECIFICALLY WE CITE THE FOLLOWING ISSUES/PROBLEMS THAT NEED TO BE RESOLVED BETWEEN AGENCIES:

ISSUE I- THERE ARE MANY MANY LENDERS CURRENTLY STILL REQUESTING APPRAISERS TO PERFORM PRELIMINARY VALUE ESTIMATES, LOOKUPS, COMP SEARCHES, ETC... WHICH ACCORDING TO THE RULES THAT REGULATE APPRAISERS, WOULD REQUIRE APPRAISERS TO EITHER PROVIDE AN APPRAISAL PER USPAP GUIDELINES OR IGNORE THE CURRENT RULES IN PLACE PER USPAP. THE PROBLEM IS MADE WORSE BY THE FACT THAT SOME APPRAISERS WILL AND DO IGNORE THE RULES AND IN DOING SO HAVE AN UNFAIR ADVANTAGE OVER THOSE THAT DO NOT IGNORE THE RULES. AND IT IS HIGHLY DOUBTFUL THAT THIS BOARD COULD EVER DISCOVER AND DISCIPLINE ALL OR EVEN A GOOD PERCENTAGE OF THOSE APPRAISERS THAT ARE VIOLATING THE RULES. WE BELIEVE THIS IS DO IN PART TO, SOME UNETHICAL APPRAISERS THAT ARE OUT THERE BUT ALSO IN PART TO THE FACT THAT THERE ARE SO MANY LENDERS OUT THERE THAT EXPECT THIS TYPE OF PRODUCT TO BE PROVIDED TO THEM IN ORDER TO EARN THEIR BUSINESS. THIS PROBLEM IS SO PERVASIVE THAT THIS BOARD ALONE ALONG WITH MANY OTHERS LIKE IT COULD NOT EVEN BEGIN TO MAKE A DENT IN CONTROLLING IT THROUGH ITS DISCIPLINARY POWERS OVER APPRAISERS. IT IS A PROBLEM FOR APPRAISERS THAT ON THE OTHER HAND IS PROBABLY NOT EVEN AGAINST THE RULES THAT LENDERS HAVE TO CURRENTLY FOLLOW. THEREFORE, WE BELIEVE THAT IT WOULD BE APPROPRIATE FOR THE BOARD, AS THE AGENCY RESPONSIBLE FOR REGULATING APPRAISERS TO AT LEAST COMMUNICATE WITH OTHER BOARDS THAT REGULATE LENDERS, REALTORS, MORTGAGE BROKERS, ETC.. REGARDING THE PRACTICES OF THOSE PROFESSIONS THAT CREATE A TREMENDOUS WORKLOAD FOR FREAB.

ISSUE II-GENERAL LENDER PRESSURE CONTINUES TO BE AN EVER INCREASING PROBLEM FOR APPRAISERS. IN OUR OPINION THERE IS A SERIOUS FLAW IN THE WAY IN WHICH LENDERS COMPENSATE THEIR LOAN OFFICERS WHICH IS AT THE ROOT OF THE PROBLEM. WE HAVE PERSONAL KNOWLEDGE OF MAJOR LOCAL BANKING INSTITUTIONS THAT GIVE COMPLETE CONTROL OVER WHICH APPRAISERS THAT LOAN OFFICERS UTILIZE WHILE AT THE SAME TIME THE MAJOR PORTION OF THESE LOAN OFFICERS' INCOMES IS BASED UPON THE DOLLAR VALUE OF THE LOANS THAT THEY CLOSE. THIS FLAW IN THE SYSTEM, WE BELIEVE HAS BEEN ATTEMPTED TO BE SOLVED TOO OFTEN IN THE PAST, PRESENT AND FUTURE BY IMPOSING ADDITIONAL REQUIREMENTS ON APPRAISERS RATHER THAN FIXING THE REAL PROBLEM. THIS BASIC FLAW IN THE WAY MANY MAJOR LENDERS ORDER APPRAISALS NEEDS TO BE FIXED. THE STATE REGULATORY AGENCY THAT OVERSEES LENDERS AND THE FREAB NEED TO MEET TOGETHER AND DISCUSS ALTERNATIVES TO THE PRESENT SYSTEM FOR ORDERING APPRAISALS BECAUSE THE CURRENT SYSTEM LEADS TO A TREMENDOUS WORKLOAD FOR THE FREAB IN TERMS OF ITS DISCIPLINARY FUNCTION.

ISSUE III- ANOTHER WAY IN WHICH APPRAISERS ARE PRESSURED BY LENDERS IS IN THE AREA OF PAYMENT FOR APPRAISALS. MANY LENDERS HAVE AND WILL CONTINUE TO WITHHOLD PAYMENT FOR APPRAISALS THAT DO NOT MAKE THEIR REQUIRED VALUES. IF APPRAISERS ARE EXPECTED TO BE THE ONLY PROFESSIONALS IN THE PROCESS THAT ARE TRULY UNBIASED, A METHOD THAT REQUIRES THE LENDER TO PAY FOR ALL APPRAISALS COMPLETED NEEDS TO BE DISCUSSED.

TO CONCLUDE, WE ARE FULLY AWARE THAT THE SOLUTIONS TO THE FEW ISSUES THAT HAVE BEEN RAISED HERE, DO NOT ALL LIE WITHIN THE AUTHORITY AND REALM OF THE FREAB. THAT IS WHY WE ASK THE BOARD TO SUPPORT A MEETING OF ALL OF THE AGENCIES INVOLVED SO THAT EACH AGENCY WILL HAVE THE OPPORTUNITY TO HEAR FROM THE OTHER REGARDING THE PROBLEMS THAT EXIST AND THAT CROSS AGENCY LINES OF AUTHORITY. WE DO BELIEVE THAT THE FREAB HAS MUCH TO GAIN BY ITS CALL FOR THIS INTERAGENCY MEETING IN TERMS OF THE POTENTIAL FOR A REDUCTION IN ITS FUTURE DISCIPLINARY PROCEEDINGS AND IN TERMS OF SIGNIFICANT PROGRESS IN DECIDING QUESTIONS OF APPRAISAL PRACTICE AND IN ESTABLISHING STANDARDS FOR REAL ESTATE APPRAISALS.
 
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