Ray & Dale too - There seems to be a lot of misunderstanding about the various state appraisal agencies and what they can and can not do.
First understand that the the concept of appraiser regulation (licensing) came out of Title XI back in '89. It was the result of a compromise between the Feds and the States in which the Feds mandated licensing but required that the various jurisdictions enforce and carry it out in within a broad set of guidelines.
The underlying mandate was to PROTECT THE FEDERALLY REGULATED LENDING INSTITUTIONS in response to the S & L failure. It was, and is, not designed to protect the appraisers or the public. Some of the states have tacked on consummer protection - not all.
When you see that lenders are leading appraisers by providing "target" values and shunning appraisers that refuse to "play ball" (that's popular out here), it does no good to complain to your appraiser regulitory board - they have not been empowered to deal with lenders. They have been empowered to issue licences/certifications, enforce USPAP and maybe a few other appraiser related matters - but that's about all they can do.
No amount of ranting, raving and board bashing is gonna change anything. One of the difficulties I see is that the various boards and regulatory agencies operate in a vaccume - they simply do not talk to one another. What if you got your appraiser board to establish a link with your state's Office of Thrift Supervision and whoever regulates/licenses mortgage brokers, Realtors and anyone else (Credit Unions...) you can think of that is trying to influence appraisers. (In my state, auditors now cite regulated lenders for putting a "value estimate" on the appraisal request).
I understand that some of you in various parts of the country feel that your boards are nothing more than political hacks intending to do nothing more than crucify local appraisers - that may be true, I don't know. I can tell you that all (or nearly all) of the various boards include quite a few appraisers - just like you and me - and that they are fully aware of the difficulties we all face as a profession.
I'm suggesting that we as a group of professional appraisers work with our various appraisal agencies to find solutions to the issues facing us all, if not, it's gonna be.......
up yours..........Oregon Doug
