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Patriot Act Affects Appraisers

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Farm Gal

Elite Member
Joined
Jan 14, 2002
Professional Status
Licensed Appraiser
State
Nebraska
OK folks:

For those new to the issue: 'Some' lenders (one in particular) are wanting Appraisers to undergo VERY close scrutiny as to their history and backgrounds and current lifestyle in order to be able to perform appraisals...

The original post which raised this concern is here:
link (It wandered a bit at the start <_< .. but there is some meat in the additional pages :( you may want to read them. )

IF I thought it would lead to the expulsion of the 'bad apples' I might ;) be all for it, but it is my opinion all this will do is create a new and better database of my and others very personal life that I personally do not feel is needed in order to be a competent and ethical appraiser. I was a government employee at one point: I have been fingerprinted and undergone the 'deep search': I have nothing to hide :usa: There was a valid reason for the process. HOWEVER, I deeply resent the possibility of having the RESULTS of that long ago search and testing be made current database material in order to be able to value a residential property!!

Here is an opportunity to sound off where it might do some good....

There IS power in numbers: give some thought on if/how you want the Patriot Act directly affecting how you do your business

I received this response:
Originally posted by "Bill Garber Director@ Government Affairs, Appraisal Institute"
The Appraisal Institute believes that some financial institutions requiring
information from appraisers may be anticipating a proposed rulemaking
recently issued by the Department of Treasury that specifically refers to
appraisers.

In my opinion, the proposed rulemaking is where our (the Appraisal
Institute and appraisal profession) attention should focus. The Treasury
rule was published on April 10 and the comment period will run until June
9, 2003.

The Patriot Act requires financial institutions to establish anti-money
laundering programs. The Department of Treasury rulemaking is soliciting
public comments on a wide range of questions pertaining to the money
laundering requirements, including how to define "persons involved in real
estate closings and settlements," the money laundering risks posed by such
persons, and whether any such persons should be exempted from this
requirement.

A few of the key questions we must address are:

1. Should appraisers be defined as something different than financial
institutions?

2. Do appraisers pose a money laundering risk? If so, how so?

I would encourage you to comment on the rulemaking prior to June 9. I
expect AI will provide official comments as well.

The proper address can be found within the rule, which I have linked below.

http://www.ustreas.gov/press/releases/repo...orts/js1751.pdf

Sincerely,

Bill Garber
Director, Government Affairs
Appraisal Institute
202-298-5586
[email protected]

So DO something :usa: :eek:nfire:
 
Joined
Jan 16, 2002
Wow Lee Ann, what a "hornets nest" this thing stirred up.... OK, I'm sending in my humble opinion comments to the big boys in government. There sure is a lot of "government speak" in that link. Unfortunately, I predict only one thing will happen, i.e. they will do as they have always done and completely ignore the appraisers (unless the banking lobby dosn't want it either).

This industry is cart-wheeling out of control and I don't know if I can put up with this garbage much longer. :blink:
 
Joined
Jan 13, 2002
Professional Status
Retired Appraiser
State
Florida
This industry is cart-wheeling out of control and I don't know if I can put up with this garbage much longer.

I feeling the same way more and more often. There's just so long I can fight the 'good' fight and sometimes lately, I feel that not only am I fighting a losing battle, I'm also just spinning my wheels for what will end up all in the hands of whomever the banks & Realtors want to rubber stamp a number for them. No one else seems to care! Except the few of us here.
 

Richard Carlsen

Elite Member
Joined
Jan 15, 2002
Professional Status
Licensed Appraiser
State
Michigan
Pray tell, how can I as an appraiser, earning $300 plus or minus for forming an opinion of value about a specific piece of real estate and writing a report about it , a property chosen by another party, conceivably launder money for terrorists?

Someone certainly has their head up a very small orifice where the sun does not laminate.
 

Farm Gal

Elite Member
Joined
Jan 14, 2002
Professional Status
Licensed Appraiser
State
Nebraska
OK Folks: how about reframing this in a more positive light:
Let us turn the sour taste in mouth into lemonade for ALL. yeah I know: rah rah rah... folks, hear me OUT!

I don't happen to believe that most of us are financial institutions, a house inspector whose only financial interest/knowlege is the check for services is even less so. I think pointed comments to that effect are needed.

but beyond that: HOW ABOUT:
Stressing in your comments the need for a FUNDED and RELIABLELY overseen Federal resource for reporting suspected cases of fraud, a place where appraisers reporting suspicions of on-going activity that needs investigation actually has some impact rather than a yawn.

WE know that lender/realtor/banking industry in general pressure is out there and that some of our competion may write a mostly USPAP compliant report that oooops misses the value by several orders of magnitude.

Many states lack the funding to properly research allegations, some lose time and effort persecuting 'good appraisers' ... abuses due to improper accusations occurr... Do you think that a properly run national databse of reports of abuse might turn up some intersting patterns!?!?!? and create some questions that maybe just maaaybe, would result in pattern identification that could benefit us all! Weed OUT some of the bad pressure and actors?!?!?

A NATIONAL (not local) database probably could start to catch some specific practices which curently go unresolved, even when we KNOW they are out there because we as individuals have no credibility nor place to complain!

Now don't hurt me because I think that maybe if we all speak loudly that perhaps we CAN be heard. Or think I want MROE oversight than we already have: how about turning the bright lights on the INSTITUTIONS!?!?!
 

jtrotta

Senior Member
Joined
Jan 16, 2002
LeeAnn

the BRIGHT lights have bean on the institutions fer so long - they wound up inventing the never ending light bulb :lol: - the problem is the people who run the Institutions are right along side the people who run the country, - yer tryin ta run uphill on a mud slope B)

what ya have ta think about is, who was the bright light that came up with the idea (as Richard notes) that anyone earning $300 - $500 a job, can set up a money laundering operation ;) Ya can't start at the bottom an work yer way up all the time cause by the time ya reach the top rung - all the money's bean mishandled already. This appears ta be a ploy to allow the "operators" a bait n switch type antics; in other words - it's allowing time for the deceitful ta git their house in order, so the great deception can take place - now don't that make ya wanna go - hmmmmmmmmmmm :mrgreen:

:ph34r:
 

Larry Lyke

Senior Member
Joined
Feb 2, 2002
Actually, I was kind of looking forward to the strip search, but the Cato Institute put a serious spin on it.

Of course, there's always a kernel of truth in every new issue. Hey, somebody somewhere is getting kudos for putting this together.

I'm willing to see part of the problem. There's so much potential to launder dirty money in the housing industry. Remember, terrorists do have money.

And this is a very easy business to get into -- and out of. You can be on the street working in as little as a month.
 
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