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another thought

Mike,

on your thoughts about the "part time" DOLS appraiser investigations...

perhaps we can see if they can appoint a special investigator who is an appraiser. I know that Ernest wants to make more/better use of his RA's. perhaps one of his better ones could do that sort of investigation. certainly worth talking to him about.

or, at a minimum, perhaps there could be a scheduled RA meeting with the investigators to let them in on some of the things we know that they could not.
like "ask specifically for the original order from the client when they request the work file" then they would know if there was "number hitting"

and for the people who say their signature is stolen? ask them what software they use. I know that with ACI you need the file and the password so it could not be stolen if it was given in the first place....

maybe all we need is better education of the existing inspectors so they can know what to look for.

thoughts?
 
send several state representitives to the School as undercover students....

do a search on this site for Fat Man, Dount guy, Dr Bill, Merrill,

That's the obvious solution. Sitting in a class one day at that school will tell all the investigators what they need to know; it's that bad. It is my understanding that some board members are well aware of this place; simply ask Dominick.

I have been told, though I don't have evidence, that the failure rate is very high at that place.
 
Making NY a "mandatory" state would be awesome, but would likely require legislation. I wouldn't be surprised to find out we are not mandatory for political reasons.


I doubt there is much that can be done to shut down the school mills.


I agree with the 5 year experience requirement for supervisories. I don't think the additional fee per trainee for supervisories is a good idea. It is very costly, time consuming and a money losing proposition (at least for the first year or so) to properly mentor a trainee. Concientious, ethical supervisors might just balk at paying a stiff fee per trainee (I probably would) and hire licensed or certified appraisers. Also I doubt the math would hold up - there is likely going to be a huge shakeout of appraisers and trainees this cycle.


I would suggest adding the supervisory appraiser and whether supervisory inspected with trainee to the trainee's log sheets for experience hours and if possible make the logs computerized - say on a dept of state web site so they can be easily checked for abuse ie a mill where dozens of inspections are supposedly being made the same day by one supervisory with many different trainees. I think FL already does something like this.


Also suggest requiring supervisory must take at least one CE course specifically addressing supervisory issues per CE cycle.
 
Making NY a "mandatory" state would be awesome, but would likely require legislation. I wouldn't be surprised to find out we are not mandatory for political reasons.

ya think???? NAR is a huge political force.

I doubt there is much that can be done to shut down the school mills.

but we can ask Ernest about that. He may just like that idea


I agree with the 5 year experience requirement for supervisories. I don't think the additional fee per trainee for supervisories is a good idea. It is very costly, time consuming and a money losing proposition (at least for the first year or so) to properly mentor a trainee. Concientious, ethical supervisors might just balk at paying a stiff fee per trainee (I probably would) and hire licensed or certified appraisers. Also I doubt the math would hold up - there is likely going to be a huge shakeout of appraisers and trainees this cycle.


I would suggest adding the supervisory appraiser and whether supervisory inspected with trainee to the trainee's log sheets for experience hours and if possible make the logs computerized - say on a dept of state web site so they can be easily checked for abuse ie a mill where dozens of inspections are supposedly being made the same day by one supervisory with many different trainees. I think FL already does something like this.

i sent the Florida regs to the vice chair. no response :shrug:


Also suggest requiring supervisory must take at least one CE course specifically addressing supervisory issues per CE cycle.

yesyesyes

i think Mike indicated the trainee pays the extra $$ not the supervisor...
 
Putting the additional fee on the trainee would not be fair either - it would smack to me of protectionism. If the budget is not sufficient, raise everyone's license/certification fee. Another way to raise money would be much stiffer fines in addition to suspension where warranted or maybe print a book - NY appraisal related law + USPAP & sell it to trainees at a profit.
 
i believe that DOLS are already looking into raising the fines.

unfortunately, it appears that fines can only be assessed in "ticket" situations. when they go in front of a judge, the judge cannot fine them, they can only reprimand them with license suspension/revocation.
 
IMO - ANY new regs, lacking enforcement funding, are doomed to the same success rate as the existing ones.

Ken - i understand your comment...... i do suggest that 1 appraisal fee per year - (i.e. 2 splits) should clearly be NO obstacle vs 100-200 appraisals annually......per trainee. i suggest the reason inadequate funding exists IS intentional - and the only way to solve the supervisory "debacle"......and end "Skippydom"........ is to provide the tool to shoot a blowtorch at

"geeeeeeee we dont have the money or the staffing". Cupple months ago I floated your idea about increasing all renewal fees......... with ZERO support. I do believe those who wish to take on more than 3 trainees should pay for the privelege of earning THOUSANDS annually - when its' earned ...Ethically and in full Compliance.

New educational or "supervisory" regs without providing budgets for ACTIVE Enforcement................are "more bandaids" destined to come loose and fall off -NOT solve the problem.
 
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I doubt there is much that can be done to shut down the school mills.


I'm actually not suggesting shutting down. I would suggest investigating, requiring changes, and followup visits. If the situation continues, then disapprove the school.

I would suggest adding the supervisory appraiser and whether supervisory inspected with trainee to the trainee's log sheets for experience hours and if possible make the logs computerized - say on a dept of state web site so they can be easily checked for abuse ie a mill where dozens of inspections are supposedly being made the same day by one supervisory with many different trainees. I think FL already does something like this.

The computerized database is likely cost effective to do. There are up front costs for design, but once and running is should be low maintenance.
 
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I'm actually not suggesting shutting down. I would suggest investigating, requiring changes, and followup visits. If the situation continues, then disapprove the school.



The computerized database is likely cost effective to do. There are up front costs for design, but once and running is should be low maintenance.



and they could use the florida model as a guide
 
IMO - ANY new regs, lacking enforcement funding, are doomed to the same success rate as the existing ones.

]New educational or "supervisory" regs without providing budgets for ACTIVE Enforcement................are "more bandaids" destined to come loose and fall off -NOT solve the problem. [/COLOR][/I][/B]

Mkie, i disagree with you on this point. as an RA i have a little more insight. Complaints are getting processed and from what i see, in a fairly timely manner (until the attorney for the defense gets involved)

the bigger problem is that the community is not turning in the bad appraisals. i went to an appraisers breakfast yesterday. 3 of the appraisers there have lots of work reviewing. they told me about some of the horrible appraisals they see. one brought pics so we could see how bad the comps were. BUT when i asked if they turned them into the state, they said no. and nothing i could say would sway them to turn them in. if the state doesnt know about a bad appraisal, they cannot investigate them.
 
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