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STD-3 and State Investigations

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Jan 16, 2002
Since so many have been interested in my opinion on this question, here it is:

I believe that state investigations SHOULD be done under STD-3, WHEN a licensed/certified appraiser is engaged to do one.

Certain investigatory functions do NOT require an appraiser. For example, an appraiser uses a comp in a report. Pretty much anyone could drive by it, pull out the MLS page(s), and get the assessor's data, and turn it over to the board.

An unlicensed appraiser does an appraisal for a FRT or in a mandatory state. Don't need an appraiser to review it to know he/she broke the law.

I say that states should not have to order a STD-3 review at every stage of an investigation; however, IF, after a FORMAL hearing, the state wishes to pursue the case and actually DO a review on the appraisal, then it should certainly conform to STD-3- and every other requirement under USPAP and applicable state laws.

I am told that Illinois will be incorporating this into their new admin rules- in its revised version.

Brad Ellis, IFA,RAA

Stephen J. Vertin MAI

Senior Member
Jan 17, 2002
Professional Status
Certified General Appraiser

You make it sound like the State of Illinois are good guys and square shooters. The only reason they made these change is because the State's original stand was opposed by all organizations in the State and they can not change rules without support from said organizations. My hats off to the brave men and women within our fine appraisal organizations in the State of Illinois that rejected OBRE's law change and stood up for what is right..

Steve Vertin


I believe Arkansas does required certified appraisers to review others. They recently complained that many of the reviews themselves were not USPAP compliant.



Last year I got a call from an investigator for the Delaware board asking questions about a mixed-use property that I appraised before the license laws. He admitted that he didn't know much about income properties and I spent about fifteen minutes with him discussing the neighborhood.

This gentleman was trying to do a good job and I tried to help him but I wondered why an inexperienced person would be assigned to review something he didn't understand. I can only conclude that the state government wants to regulate appraisers in the cheapest way possible, just like Fannie Mae, HUD and the lenders.
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