Charlotte - you say "I performed a 1004 URAR appraisal on a townhouse in Dover, Delaware, (my market area) and that appraisal was reviewed by a State of Oregon appraiser. I kicked and screemed because the reviewer made some very specific corrections/comments to my report, as to distance to comps, end units vs. interior units, etc. I contacted the Oregon Board of Appraisal Reg and they said that the State of Delaware is responsible for monitoring complaints in their state. My state board in Delaware said it was the responsibility of Oregon to monitor their licensees. "
As I recall, the first issue to be resolved was to identify the reviewer as the review report was unsigned. I believe that was done.
The second issue was to ascertain the jurisdiction in which lodge a complaint. Because the property is in the state of Delaware, the appraisal activity - and by extension - the review activity was within the jurisdiction of Delaware (not Oregon). The questions then are: Is Delaware a manditory state - is the appraiser/reviewer required to be licensed in Delaware? If the answer is yes, then obviously Delaware needs to initiate the complaint and investigation regarding the reviewer's license status and geographical competance regarding the Delaware market.
It is the responsibility of the Oregon Board (ACLB) to monitor appraisal/review activities of those licensed/certified appraisers in the state of Oregon (a manditory state). The Oregon Board will investigate complaints filed against Oregon Appraisers for USPAP violations and non licensed/certified Oregon residents performing appraisals of properties in Oregon. I assume that Delaware is similar.
I don't see how an Oregon Investigator would be able to adequately investigate a complaint involving a property in Delaware - the investigator would lack the requisite geographical competance. Without that local knowledge, it would be difficult to perform an investigation regarding alledged developmental matters (SR 1) or reporting violations (SR 2).
You're right - it is a loop hole, no matter what. I don't know what the answer is (national license?) but I'll keep asking questions.
Oregon Doug