Title Xi 2004 Georgia's Board Was Correct!

[Bob Ipock]

The only $$$ diverted from the state to the ASC is the National Registry fees which the state COLLECTS from appraisers and then passes along to the ASC,

In NC, the NCAB collects $45.00 and then sends only $25.00 of it to the ASC,
and pockets the other $20.00. So much for diversion of $.

Secondly, the primary purpose of these created appraisal boards is to comply with FIRREA and ASC regulations in order for FRT's to continue in their states.

A reasonable place to start for judgement of appraisal boards would how well they have complied with the ASC, the US Congress and their own mission statements.


http://www.ASC.gov/html/frameSet.aspx?assetPath=/uploads/Rules\All ASC Rules.pdf

 

[Ben Vukicevich SRA]

"We have found that some States have dismissed complaints
containing obvious USPAP violations when the State concluded that there was “no harm to the
public.”
That is not adequate for Federal purposes under Title XI of the Financial Institutions Reform,
Recovery, and Enforcement Act of 1989 (“Title XI”). The occurrence of any USPAP violation is
significant, and deserves an appropriate State sanction.

......
Unlike the
regulation of other professions, the regulation of real estate appraisers contains a significant
component of Federal interest requiring States to enforce the Appraiser Qualification Board’s
qualifications for certified real estate appraisers and the Appraisal Standards Board’s USPAP. In
sum, when determining “harm,” please ensure that you consider these duties under Federal law,
i.e., Title XI."

Part of 1999 letter to DE Board from the ASC..

So much for states rights.

Actually, I'd rather be a doctor. You can kill people in NJ, admit guilt and still keep your license AND find employment.

Try that with a USPAP violation that caused no harm on your record.

 

[Bob Ipock]

Ben,

Any state that chooses may close down their appraisal board tomorrow. They do not need to comply with FIRREA, ASC or Title XI.

However, if they want the FEDERAL GOVERNMENT to guarantee loans in their states....they must comply.

If you don't like the rules, there is no requirement to play.

 

[Mike Kennedy]

The only $$$ diverted from the state to the ASC is the National Registry fees which the state COLLECTS from appraisers and then passes along to the ASC,

In NC, the NCAB collects $45.00 and then sends only $25.00 of it to the ASC,
and pockets the other $20.00. So much for diversion of $.

Secondly, the primary purpose of these created appraisal boards is to comply with FIRREA and ASC regulations in order for FRT's to continue in their states.

A reasonable place to start for judgement of appraisal boards would how well they have complied with the ASC, the US Congress and their own mission statements.


http://www.ASC.gov/html/frameSet.aspx?assetPath=/uploads/Rules\All ASC Rules.pdf

---------

THEN http://appraisersforum.com/redirector.php?url=http://www.gao.gov/new.items/d03404.pdf

 

[Mike Kennedy]

Mike,

See page 21 of the ASC Annual Report at the link below. The audited financial statements of the ASC start there.

http://www.ASC.gov/html/frameSet.aspx?assetPath=/uploads/Annual%20Reports\ASC2006AnnualReportFinal.pdf

The Appraisal Foundation publishes their financial statement in an annual report too.

http://www.appraisalfoundation.org/s_appraisal/bin.asp?CID=5&DID=1044&DOC=FILE.PDF

The 2006 Report is at the link above. Page 16 for the Financial Statement. The Appraisal Foundation, a not-for-profit educational foundation, has netted over $1,000,000 (income over expenses) in the past two years. Their assets in "investments" are nearly $2,000.000. Grants from the ASC to the AF are nearly $1,000,000 annually.

while maintaining a current $7 Million Fund Balance ("War Chest") accruing Interest apparently.

Thanks for the links.!

 

[Ben Vukicevich SRA]

if they want the FEDERAL GOVERNMENT to guarantee loans in their states....

?????

 

[Bob Ipock]

Title XI and the AAC are concerend with appraisals on loans that "could expose the United States government to financial loss". Title XI and the ASC are not concerned with appraisers that are not on the National Registry nor any appraisals they might produce.


Our Mission (The ASC)

The ASC's mission is to ensure that real estate appraisers, who perform appraisals in real estate transactions that could expose the United States government to financial loss, are sufficiently trained and tested to assure competency and independent judgment according to uniform high professional standards and ethics.

 

[Ben Vukicevich SRA]

USPAP C,

Very good.

The government guarantees DEPOSITS not loans.

 

[Bob Ipock]

Ther FDIC guarantees deposits. There are numerous types of loans guaranteed by the federal government including SBA, VA, farmer loans, loans to American Indians.......

 

[Francois K. Gregoire]

Ben,

Any state that chooses may close down their appraisal board tomorrow. They do not need to comply with FIRREA, ASC or Title XI.

However, if they want the FEDERAL GOVERNMENT to guarantee loans in their states....they must comply.

If you don't like the rules, there is no requirement to play.

Uncle Sam conveniently puts states over the barrel by requiring the licensing and regulation of appraisers as a condition of allowing "Federally Related Transactions" in the state. Title XI makes no mention of Federally Guaranteed Loans.

There is much more to say, but what's the use.