Question for HUD/FHA

[Don Clark]

If HUD/FHA will discontinue use of State Lacensed Appraisers as of October 1, 2009, will HUD/FHA still allow Trainee's to provide "Significant professional assistance" in the performance of the appraisal and in the reconcilliation of value? See Protocol. Seems to me that HUD/FHA would not want to allow that since they have decided that the Licensed level is not adequate for FHA Appraisals.

http://www.HUD.gov/offices/adm/hudclips/letters/mortgagee/files/41502xd.doc

 

[Mike Boyd]

FHA has never allowed a trainee to SIGN a report even if a certified appraiser signs along side. As part of their training I have had trainees make their own set of field notes and their own sketch and then compared them with mine. At first, their notes and sketches were almost laughable but it didn't take long for them to "get the message." In CA a trainee must have a trainee's license which means taking coursework and passing a test.

I notice their participation in the reports for FHA but they only sign as trainees on non FHA work.

 

[Don Clark]

FHA has never allowed a trainee to SIGN a report even if a certified appraiser signs along side. As part of their training I have had trainees make their own set of field notes and their own sketch and then compared them with mine. At first, their notes and sketches were almost laughable but it didn't take long for them to "get the message." In CA a trainee must have a trainee's license which means taking coursework and passing a test.

I notice their participation in the reports for FHA but they only sign as trainees on non FHA work.

I never said anything about them signing a report. I was trying to make the point that FHA will allow them to provide significant professional assistance but wants to eliminate the licensed appraiser. Seems contrary to the reality that a licensed appraiser is more qualified than a trainee.

 

[Anthem]

I never said anything about them signing a report. I was trying to make the point that FHA will allow them to provide significant professional assistance but wants to eliminate the licensed appraiser. Seems contrary to the reality that a licensed appraiser is more qualified than a trainee.

Significant assistance from a trainee accompanied by a Cert who is signing, inspecting and approving the report is a bit different than License doing the report them self. Seems like a no brainer to me.

The idea is the Cert is actually training the trainee, unfortunately often the trainee is a blind person filling in the blanks but when writing law they must ignore this sad fact and be optimistic that the signing cert is doing the entire report and on top of that training the person holding the dumb end of the tape

From a legal point of view it is still a cert signing vs a licensed signing.

 

[Don Clark]

Significant assistance from a trainee accompanied by a Cert who is signing, inspecting and approving the report is a bit different than License doing the report them self. Seems like a no brainer to me.

The idea is the Cert is actually training the trainee, unfortunately often the trainee is a blind person filling in the blanks but when writing law they must ignore this sad fact and be optimistic that the signing cert is doing the entire report and on top of that training the person holding the dumb end of the tape

From a legal point of view it is still a cert signing vs a licensed signing.

I get the point. But, FHA could require that professional assistance only be provided by a Certified Appraiser. That would clear up a little of the mud. BTW, I expect a revision to the idea of Certified only before October 1, 2009.

 

[Mike Boyd]

I get the point. But, FHA could require that professional assistance only be provided by a Certified Appraiser. That would clear up a little of the mud. BTW, I expect a revision to the idea of Certified only before October 1, 2009.

Do you expect the feds to be that creative?

 

[Anthem]

BTW, I expect a revision to the idea of Certified only before October 1, 2009.

Not sure I would join in that prediction. FHA is just one of many who are getting away from Licensed appraisers. Many influential people in the AARO, AF etc have been hinting that soon all states will get rid of the licensed level and we have seen many states join in .... IMHO the only reason more have not is they fear they will lose to much revenue.

 

[Mr Rex]

I think there may be a revision as well, like an ASB announcement that the License category will be phased out completely by the end of 2010 or so.

 

[Don Clark]

I think there may be a revision as well, like an ASB announcement that the License category will be phased out completely by the end of 2010 or so.

The ASB has no such authority, only the states.

 

[Mr Rex]

The ASB has no such authority, only the states.

Perhaps I should have said AQB. If the folks that create the licensing standards do away with a license level, then surely the states will have to follow, eventually....