Question for HUD/FHA

[Don Clark]

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....

The License Level was not created by the AQB or the Appraisal Foundation. It was created by FIRREA, a federal law.

 

[Mr Rex]

The License Level was not created by the AQB or the Appraisal Foundation. It was created by FIRREA, a federal law.

Not in for a chicken or egg debate:

Under the provisions of Title XI of the Financial Institutions Reform, Recovery and Enforcement Act of 1989 (FIRREA), the AQB establishes the minimum education, experience and examination requirements for real property appraisers to obtain a state certification.

 

[Don Clark]

Not in for a chicken or egg debate:

Under the provisions of Title XI of the Financial Institutions Reform, Recovery and Enforcement Act of 1989 (FIRREA), the AQB establishes the minimum education, experience and examination requirements for real property appraisers to obtain a state certification.

And, FIRREA refers to both Licensed and Certified.

http://www.AI-ct.org/firrea.html

 

[Mr Rex]

And in a circular manner, we come back to 1116,d that allows FHA to change their criteria.

On the other hand, you are saying that the AQB cannot eliminate the licensed category, a state can. Firrea would have to be changed to make it a national standard?

 

[Anthem]

Rex,

We have been hearing the same type of stuff ... I believe the License level will be obsolete in the very near future we can debate on how all day but when the level is either gone or worthless it won't matter

 

[Mike Garrett RAA]

I think the AQB can and does set certain criteria for licensing and certification which is then given to the states so that they can create their license law. I, too, am of the impression the license level will be going away.

In the Guide for Understanding the 2008 Real Property Appraiser Qualification Criteria which took affect January 1, 2008 it stated:

"States are required to implement appraiser certification requirements that are no less stringent than those issued by the AQB".

It also said..."The AQB is aware that it has not statutory authority to develop criteria for the licensed and trainee classifications and the states are not required to adopt the criteria."

In the Executive Summary of the 2008 Qualification Criteria it only lists Certified General and Certified Residential. All of the publications are available on line at the Appraisal Foundation website.

 

[Don Clark]

"States are required to implement appraiser certification requirements that are no less stringent than those issued by the AQB".

It also said..."The AQB is aware that it has not statutory authority to develop criteria for the licensed and trainee classifications and the states are not required to adopt the criteria."

In the Executive Summary of the 2008 Qualification Criteria it only lists Certified General and Certified Residential. All of the publications are available on line at the Appraisal Foundation website.

My point exactly Mike. Licensed level and trainees are a function of the state.

 

[Ted Markow]

My question is who has determined that when an appraiser becomes Certified that competency and ethics change/improve? I dare say that those numbers are similar for both licensed and certified appraisers and if the feds have their way, the number of unethical incompetent appraisers will increase for certified on or around October 2009. I wonder who decided that making Certified the minimum requirement for FHA would improve the level of competent reports? The maximum transaction amount for FHA does not exceed the limit for an Licensed Residential. First they eliminate the full featured testing for FHA then the reduce it to ten questions verbatim from the handbook. After that they realized that they needed to attract more appraisers to the rooster in order to cover increasing number of loan applications. Now once again they are running scared but in the opposite direction. Where does it all end and what happened to the grandfathering? They need to consider some middle ground instead of penalizing those licensed appraisers who met the requirements at the time they applied and take the job seriously producing credible reports. I think they over reacted when they eliminated all the requirements and once again changing the license level.

 

[Mike Garrett RAA]

Think what you will...it's done.

I am a pilot and hold a private pilot's license for single engine land aircraft. Would you say I am as qualified as someone who holds an Airline Transport Pilot (ATP) license? Hardly! Just for the record, I am not current and haven't flown as pilot in command for years. The point is...higher license levels or certifications demonstrates a persons ability and training.

Certified Residential Appraisers should be more experienced, have additional training, and better qualified to do certain assignments than licensed appraisers. Granted there are those who hold certifications that are hacks. That holds true at the license level too.

 

[jakeboeger]

Just another bonehead move by the government. I thought we were supposed to be creating jobs!

Are good licensed appraisers less qualified than good certified appraisers?

Are crappy certified appraisers more qualified than crappy licensed appraisers?

Where I come from good is good and crap is crap!