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The New USPAP

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We are not CA. How many appraisers do you think are here? ~1,000. 10% of CA? and how many complaints were filed there? 250 or so was the latest figures I found. Still more than against architects, engineers, CPAs and lawyers percentage wise.

And changes related to that when they lost the case to the attorney-appraiser was most telling. Further, we saw fewer complaints with time, which might be a natural benefit to having had a very aggressive investigator or two. We had a forumite whom I knew who was so disgusted with the MAI we had for an investigator, that he didn't wait for the board, he just handed him his card and walked out without a word. That's not a disciplinary situation. I've seen his work. He was a Little Rock appraiser and did 2 houses for me in an estate I was doing elsewhere. The reports were fine. But he had a Realtor he had killed one of his "deals" file every time he or his wife was on one of her sales. His wife said "F this" and went to work for the county assessor. Another on this site was going to law school and this same MAI who apparently thought every appraisal was supposed to be an MAI demonstration report, accused him of "lawyering up" over the contribution of the rare basement in the area. He quit because he was weeks away from sitting for the bar and didn't want that on his record if he lost. A year later I found him as an intern at one of the biggest law firms in Little Rock. Tell me he couldn't "understand" USPAP. Thank goodness that MAI investigator got sick and had to retire. If he hadn't there would be 45 appraisers left in the state and they'd all be MAIs.
Stick to the question. Based on the actual number of disciplinary actions over the last 10 years, do you think your state's appraisal board has been overactive relative to the actual level of misconduct in your state?
 
Based on the actual numbers over the last 10 years, do you think your state's appraisal board has been overactive relative to the actual level of misconduct in your state?
Not after the punishment they were meted out in courts rejecting and reversing them. They tempered their nonsense and part of that relates to how aggressive their investigator was. But it changes nothing about volume. The question is why would we want a board that revokes a license? you are screwing with someone's livelihood. Further, in the broadcast you obviously didn't bother to listen to, these FNMA tips can and undoubtedly will cause a lot of people to be sanctioned and once sanctioned you will never be able to be an expert witness without getting your guts ripped out. Again, even the governor cannot pardon you from such board actions twenty years later. It's on file forever. Further, without so much as helping the investigators, FNMA simply says "Oh, maybe an USPAP violation." Let the board do their dirty work while the appraiser has to pay a lawyer to go to the board. And anyone thinking they should go to the board or the investigator WITHOUT a lawyer, has a fool for a lawyer -themselves. No country for amateurs. And E & O does not pay for everything.
 
So should I read your response as amounting to an acknowledgement that - regardless of how they started - over the last 10 years they haven't been acting too aggressively?

If someone is lying, cheating and stealing in an appraisal then I very much want their license to be revoked. If someone is single signing "did inspect" then I want at least a suspension and a fine for that, if not the revocation.

One fundamental purpose of licensing is to take the worst of the worst out of circulation. Fck them.
 
.. but they know BS when they see it.

Yes and that BS is called TAF and USPAP. A bunch of white-collar criminals writing standards, rules, and ethics and becoming wealthy from it. Only in America. Lol
 
The best general definition is: "Competence is the ability to effectively and efficiently perform a task or role to a high standard. It encompasses a combination of knowledge, skills, behaviors, and attitudes that enable an individual to achieve successful outcomes in a specific context or job function. Competence implies not only having the necessary qualifications and expertise but also the capacity to apply them appropriately in different situations."

We need a standard or protocol for determining degree of competence. Such a standard might attack the problem from different angles, that is different kinds of tests.

Competence in doing a complex task, is not just dependent on the person doing the task - but also the infrastructure and tools at his disposal. A trained surgeon of many years cannot be expected to successfully remove a stomach cancer without a satisfactory operating area and surgical tools. An auto mechanic with years of experience taking engines and transmissions apart and reassembling them will need al kinds of equipment plus reference books on the engines he is working on that layout the steps to take in execcuting certain procedures. Engineers need standards to effectively design buildings and bridges that meet the approval of government authorities - without having to redo all of their work.

99+% of appraisers do not have the supporting infrastructure of good standards, nor the statistical knowledge and computer assets to do good appraisals in complex residential areas. So I assert that most residential appraisers do not have the competence to do good work in complex areas because of the lack of supporting infrastructure such as satisfactory standards, lack of specific education on the use of advanced statistical tools such as MARS and R, and in some cases a lack of minimum intelligence required to do the job.

Now, needless to say, many existing appraisers don't know what they don't know, so I am wasting my time communicating the above to most.

Tests

1. Differing Values: Given reasonably good sales data, if you have two appraisers that differ in their value conclusions by more than 5%, then there are definitely flaws in the appraisal standards and/or the personal competence of at least one of the two appraisers.

2. Value conclusions are supported by two types of data: (a) Critical measurements (such as GLA and Lot Size) and (b) Explanatory data that simply attempt to explain the residual value. The explanatory data (such as verbal or approximate condition, quality, aesthetics) does not have to be accurate or even correct but should be a best attempt, as they don't impact value since they are protected by a firm residual value. But the critical measurements should be a best attempt at accuracy. If a review appraiser can find a more reasonably effective way to improve the accuracy of critical measurements, then that questions the accuracy of the original appraisal. In particular, if the reviewing appraiser can improve the accuracy of the appraisal by more than 5%, that certainly is an indicator of incompetence. Understand that 5% is not a Golden Standard - it is a suggested Minimum Standard. A good standard should lead two or more independent appraises to value conclusions that are within 1% of each other, although admittedly critical measurements often have to be at least partially estimated. There might be extreme cases where more than 5% deviation must be allowed because critical measurement accuracy is not possible beyond a certain degree, i.e. rough estimates have to be relied on. And a good standard should provide guidance on what degree of accuracy in estimation is required, - there has to be limits. If you can't get reasonable estimates of building area and lot size, then the best you can do if probably some large range - that might very well not meet the given SOW, - leading you to reject the assignment.

3. No one can find any correctable flaws in the appraisal, including measurements or value conclusion, that are improvements to the original appraisal, beyond a shadow of doubt. If you are the best, the only question, is whehter your procedures meet the agreed upon standards and SOW.

... I am sure we could think of more.
Thank you for your thorough reply. I didn't actually expect you to give a meaningful reply beyond attacking me personally and giving a 1000 word dissertation on why your AVM is super bestest most excellently awesome.

For the most part I agree. The parts where you kept it on subject are good. You did venture off topic and ranted a bit. However, was not condescending. Thank you
 
And then you did this... I take back the part where I said meaningful.

To be clear, please understand that there are areas ( mostly out in the sticks or vacation areas with a very slow turnover in properties ) where low R2 values are endemic - maybe as low as 40%. Here again, we need a better standard on dealing with these. Whatever model you come up with is not going to be that reliable. MARS may not even be able to provide a CVR2 value (cross-validated R2 from running on many different partitions of your data set where 4/5ths or 9/10ths are used to create the model and the remaining 1/5 or 1/10 used to test it). -- In such areas, appraisers could be easily off in value by far more than 5%. But, then, your low R2 and CVR2 (assuming you can get one) are proof of what you are dealing with. In such cases I would attempt to prove a minimum and maximum value to give a range and if a point value is required take some interior point of the range - for what it is worth.
 
If someone is lying, cheating and stealing in an appraisal then I very much want their license to be revoked.
So how often is actual fraud uncovered? 99% of the time, it's poor development of comps, poor selection of comps, not using land sales when they are available, or say missing a pool in the back yard on a comp. Is that "lying", "cheating", or "stealing"?

I want someone who physically steals from a house lose their license. i want someone who makes up comps that don't exist to lose their license. I want someone who fabricates "facts" in lieu of actually researching comps, etc. But the guy who adds the enclosed finished sunroom or porch in the GLA??? Misses a basement being finished? I know one where the appraiser mis-measured the garage. Another where an appraiser was canned for not saying there were junk cars on the property. Apparently, the borrower thought he should have included them in the value. Another got canned over forgetting to label the report "as proposed" since the property owner was going to add a shop to the property He took the course to get back in standing and quit. Returned to banking.

When I submitted a report to the state for upgrading to CG, the reviewer rejected it saying I did not label it "Limited"... because I had made the statement that the building was in an area where there were limited comparable commercial buildings and I had expanded the area I searched to an adjacent town. My mentor was furious when she found out I got dinged. And the guy even circled "limited" (back in the paper days) - of course, this was back in the day when "limited" meant something (stupid) supposedly. I sent the report to a reviewer I knew and he came back with a sort of "WTF?" statement. He found nothing wrong but I had to submit additional reports which my mentor and I looked over to make sure the word "limited" did not appear. Then I got my license. I was reviewed by an idiot... Of course you think we are always reviewed by geniuses who are always right and never lie. And boards don't go after appraisers except the absolutely crookedest of the crooked. No, sanction is by serendipity not any systematic search for actual crooks.
 
Thank you for your thorough reply. I didn't actually expect you to give a meaningful reply beyond attacking me personally and giving a 1000 word dissertation on why your AVM is super bestest most excellently awesome.

For the most part I agree. The parts where you kept it on subject are good. You did venture off topic and ranted a bit. However, was not condescending. Thank you
I often reply to idiots, not because I appreciate their intelligence - it is just an excuse to write something for the exercise of writing something. And it's a way of putting the idiots to some constructive user, - I suppose.

Well, yes, come to think of it maybe they aren't really idiots, at least not all of the time. But they sure don't try very hard to be otherwise.
 
I often reply to idiots, not because I appreciate their intelligence - it is just an excuse to write something for the exercise of writing something. And it's a way of putting the idiots to some constructive user, - I suppose.

Well, yes, come to think of it maybe they aren't really idiots, at least not all of the time. But they sure don't try very hard to be otherwise.
I should be more mindful of your knowledge in appraisal theory and not dismiss you as an AVM wanna be. I should just except I'm too stupid.

I have often thought we could come to an agreement on at least one matter, but then we would both be wrong. I praise you on your many years of experience. Intelligent thoughts have always followed you, but you are faster.
 
I praise you on your many years of experience
As far as being a credentialed appraiser. He has fewer years than many on this forum. Has only been a CG for 4 years. It would appear that the majority of his experience is in the engineering field. IMO. He has always been an engineer first and appraiser second and his posts over the years seems to confirm my opinion. Everybody on this forum should take note that the methods he adamantly supports. Are actually the same methods that many are of the opinion will be the methods that minimize the actual need for appraisers
 
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