Please note these are not USPAP compliant reviews as per standard 3 of USPAP.

[PropertyEconomics]

Not my problem.




They could just change the name of the product to a BRO - Broker's Reconciliation Opinion :new_smile-l:

Wouldnt work ... if you offer an opinion of value in NM not associated with obtaining a listing (or an opinion of value if you are paid for that opinion) .. you have to be licensed as an appraiser .... I believe NM has it right in this instance.

 

[John Hassler]

Wouldnt work ... if you offer an opinion of value in NM not associated with obtaining a listing (or an opinion of value if you are paid for that opinion) .. you have to be licensed as an appraiser .... I believe NM has it right in this instance.

I wholeheartedly agree.

 

[William K]

‘‘(e) MANDATORY REPORTING.—Any mortgage lender, mortgage

broker, mortgage banker, real estate broker, appraisal management
company, employee of an appraisal management company, or any
other person involved in a real estate transaction involving an
appraisal in connection with a consumer credit transaction secured
by the principal dwelling of a consumer who has a reasonable
basis to believe an appraiser is failing to comply with the Uniform
Standards of Professional Appraisal Practice, is violating applicable
laws, or is otherwise engaging in unethical or unprofessional conduct,
shall refer the matter to the applicable State appraiser certifying
and licensing agency.​

Just as an added note appraisers need to understand not everything in the new Financial Reform law protects the appraiser.... so when you go ahead and complete a NON- USPAP Compliant review or Appraisal... just remember.......:new_snipersmilie:​

​

​

 

[Carnivore]

subpeona power...

better not undercut your competition, you just might find yourself standing in front of the board..

 

[George Hatch]

Making the reviews compliant would be the responsiblity of the appraiser .. not of the company that employs them.

I keep reading on this forum about USPAP compliance and competency as it relates to AMCs and other companies ... USPAP does not govern AMCs and those other companies .... compliance and competency are the SOLE responsibility of the APPRAISER .... Im shocked that so many simply dont get this.

In the broadcast, I believe the company is putting you on notice that the work they require will not comply with USPAP Standard 3 ... which should state to the appraiser ... YOU MUST DO ADDITIONAL WORK to protect your license.

Obviously there's no substitute for an appraiser looking out for their own position with respect to compliance with standards. However, I think I could argue in opposition to the idea that "AMCs are not responsible".

Whomever put their policy together and developed their form was engaged in an activity that would fall under the broad category of appraisal practice, those activities being subject to the applicability of USPAP. In my state AMCs now have to register with the state and they have to designate an individual who will be the responsible party and subject to the jurisdiction of pour state appraisal regulatory agency for the company's conduct in such activities.

Moreover, the new Financial Overhall bill that was just signed into law places obligations on the AMCs to toe the line with respect to their conduct with appraisers and USPAP.

Depending on how the MA board currently handles the AMCs I think this one might be walking on thin ice.

 

[Lobo Fan]

AMCs should have to comply with USPAP. They keep pushing appraisers into darker and darker places with low fees, fast turn times, and now new products. I agree that ultimately it is up to each individual appraiser to draw the line in the sand. The AMCs have to be responsible for their actions. They can flaunt the rules and hide behind the individual appraiser. This is pure BS.

 

[Smokey Bear]

So.... I've yet to see what this report is supposed to look like, what the scope of work is, etc. Seems like a lot of conjecture here on something we don't know much about?

 

[Kevin Mc]

· Provide a final reconciliation value




Please note these are not USPAP compliant reviews as per standard 3 of USPAP.

Dear Pro-Teck review appraiser. Please Note that these non-USPAP compliant reviews will be fowarded to every State Appraisal Board if the opportunity presents itself.Best of luck.

 

[PropertyEconomics]

Obviously there's no substitute for an appraiser looking out for their own position with respect to compliance with standards. However, I think I could argue in opposition to the idea that "AMCs are not responsible".

Whomever put their policy together and developed their form was engaged in an activity that would fall under the broad category of appraisal practice, those activities being subject to the applicability of USPAP. In my state AMCs now have to register with the state and they have to designate an individual who will be the responsible party and subject to the jurisdiction of pour state appraisal regulatory agency for the company's conduct in such activities.

Moreover, the new Financial Overhall bill that was just signed into law places obligations on the AMCs to toe the line with respect to their conduct with appraisers and USPAP.

Depending on how the MA board currently handles the AMCs I think this one might be walking on thin ice.

George while I dont disagree with you ... the responsiblity of compliance remains on the back of the appraisers they hire. They, for example, cannot possibly determine competency ... only an appraiser can determine if they are competent to perform an appraisal. State regulations are fine, and the Financial Overhaul Bill is also fine .. but the onus remains with the appraiser with respect to USPAP.

For years AMCs have hidden behind the appraiser ... I do not think it wise to think Appraisers can now turn the tables and hide behind requirements imposed on AMCs. Surely it is time for Appraisers to stand up and take ownership of their profession, do professional work, do USPAP compliant work, and to turn down AMC work that violates USPAP compliance or advocates non compliance.

The ball is (and always has been) in our court so its time to step up or step off.

 

[Lobo Fan]

George while I dont disagree with you ... the responsiblity of compliance remains on the back of the appraisers they hire. They, for example, cannot possibly determine competency ... only an appraiser can determine if they are competent to perform an appraisal. State regulations are fine, and the Financial Overhaul Bill is also fine .. but the onus remains with the appraiser with respect to USPAP.

For years AMCs have hidden behind the appraiser ... I do not think it wise to think Appraisers can now turn the tables and hide behind requirements imposed on AMCs. Surely it is time for Appraisers to stand up and take ownership of their profession, do professional work, do USPAP compliant work, and to turn down AMC work that violates USPAP compliance or advocates non compliance.

The ball is (and always has been) in our court so its time to step up or step off.

I agree with all of this, but I still think that the AMCs should be responsible for the quality of the reports they procure. Until they are, they will continue to pressure appraisers with lower fees, faster turn times, and dubious products. Once they are held responsible for the report, they will be encouraged to find better appraisers, pay higher fees, and allow adequate time, and stay away from nebulous products. The pressure is always for faster and cheaper. It is going to spiral out of control eventually.