Mr. Vogel,
Moving past your emotional whiplash and striking out at all of us for the problems associated with your own web site, I think I'll break this down.
<snip> ....... 704 REPORTS: My largest 2 clients are Credit Unions (portfolio), they REQUEST 704 reports and have been for 4-5 years. This is 50% of our income. It's not hard to have 4 appraisers and a typest complete 1,200-1,500 reports a year when 50% are 704 reports.
I will certainly give you that any reporting format can be made to comply with USPAP even when they do not originally. Personally, I would have tried to get those Credit Unions to be happy with the 1996 version of the 2055 form myself. The old 704 is so dated that sending it out with USPAP violations is highly possible. I do not recall you originally saying you had a staff that did 1,200 to 1,500 reports a year..... you said you did that many. So perhaps you should acknowledge that leaving a false impression was your fault, not the fault of forum members.
I noted that those of you who viewed my web page developed back in 1999 and unchanged notes in plan ENGLISH "We do not guarantee values", but all picked on COMP CHECKS. In the ever evolving USPAP that seems to change EVERY year, their are more "grey" areas than "black & white". I offer my clients a service, after 19+ years in the market and 10,000+/- reports written or reviewed I think know values in areas. When a MB or lender asks if 123 Smith St could be worth $ 1 Million, I do not research, open a file, or give a range. I say NO, it can't be done. That is a common courtesy to clients, too not waist time of money.
Here is what I really note. The fact is
you are in control of your own web pages at your web site. And the Ethics Rule has a section about advertising in it. Using the excuse of not having updated your own web site advertising since 1999 does not sound workable. If your advertising is found to be negligent by an appraisal board, good luck with the excuse. It will still violate USPAP regardless of your claiming procastination in getting your web site updated.
Next, your years in service do not excuse you for making, nor make you immune from, USPAP violations. Providing a "Less Than" value opinion based upon a client supplied benchmark ($1 Million), without creating a supporting work file, a log, developing a SOW, etc., just might be a USPAP violation. Last I checked anyway. I am not incorrect am I? That MBer question has an obvious intended use behind it. You can personally attempt to label this as "common courtesy," if you want, but the rest of us on the forum know it for exactly what it is. It is obviously beyond time you stop kidding yourself. An oral report, with no Ethics Rule "Record Keeping", and no Standards One and Two compliance, just might be a USPAP violation or two. In fact, it
is several of them I think, maybe I am incorrect, anyone wish to debate it? I might learn something! I am here to learn!..
The COMP CHECK I believe USPAP is concerned with is the opening of a file, doing preliminary work, research MLS and giving a small range of value for free, in order to "obtain the assignment". That is what I do NOT do.
Well, I guess you sure have that part correct. Because what you describe above would at least be mostly in compliance with USPAP, except doing it while attaching it to become a predetermined value for a following assignment. You, on the otherhand, are
completely violating USPAP if you are tossing out casual oral reporting with "Less Than" value conclusions with none of the above at all.
In 1999 I was contacted by some investigators regarding "appraisal fraud", It was suggested that my website contain an "Appraisal Change Order". This was filled out by unsuspecting MB and lenders hundreds of times asking for some very unreasonable and illegal changes. WE GOT IT IN WRITING. Who do you think has provided thousands of documents to the AG offoce to put these guy's on alert? Before you castrate ask.
Fantastic! And you went ahead and did this clandestined act, for the benefit of all the rest of us I suppose, using your own company name on it and leaving it there since 1999 for why? Today you publically declare yourself to be a nine year snitch against MBers that have used your web site huh? Well ehhhhh gosh!
Thanks! I do appreciate your hard work! Hope the public declaration does not hurt your business. .. Say, I think you can take that down now off your web site. You've martyred yourself for our cause enough for one day and I bet it's no longer needed... huh? .. Mission accomplished!
I am very humbled to know the
real reason a person would make their operations look so bad to others in their trade. It was they have really been helping me. Or people like me in their location. Out of my deepest gratitude I really wish I could have suggested to you sooner that you not use your own business web site for that, and forgo the public admission of your activities. I now only wonder how many of those requests were made by your two best clients that represent 50% of your business? Ouch! Maybe it was the other 50%... I hope so.
Webbed.