When is a Review Required to meet Std 3?

[Joyce Potts]

Thanks.
Now I'm wondering if those "doctors" working for hospitals are actually licensed "doctors" or are just medical checkbox low fee folks, where no medical license board has jurisdiction to due their employment status.


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Excellent analogy. Based on Terrel, they get a pass.

 

[Terrel L. Shields]

Thanks.
Now I'm wondering if those "doctors" working for hospitals are actually licensed "doctors" or are just medical checkbox low fee folks, where no medical license board has jurisdiction to due their employment status.


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Different situation. And lots of PAs, DAs, & RNs "do" procedures under a doctors supervision. And they aren't standing there watching either. Same for engineers. The man signing the drawings didn't draw them. I designed waterlines and did flood routing but I didn't sign the title block. The bank is required to review the work of appraisers. The depth of that review depends upon the complexity and risk of the loan. What a review appraiser working for the public does v what a reviewer for a bank is different. And if a certified appraiser worked where you had to comply then the bank would require them to drop their license. You have too many reviews to do in a day to write detailed reviews. Ditto evaluations. And independent evaluators here that were appraisers had to drop their license to do evals. A past forumite does Evals and making a better living than before. Plus still has his RE license on the side. They do evals to half the price of appraisals but do 3x as many, don't need E & O OE expensive CE and appraisal licenses.

 

[Joyce Potts]

You are totally and probably purposely veering down different roads that are off topic.

 

[Terrel L. Shields]

You are totally and probably purposely veering down different roads that are off topic.

How so? A certified appraiser who is a direct employee of a bank does not have to comply with USPAP. Federal bank law trumps state appraisal laws.

 

[Joyce Potts]

Terrel, in my example, was the Reviewer an employee or a fee appraiser hired to do the appraiser, just like I was hired to do the original appraisal?

Secondly, can you cite the federal regulation where a certified appraiser is exempt from USPAP if a bank employee, please?

 

[George Hatch]

How so? A certified appraiser who is a direct employee of a bank does not have to comply with USPAP. Federal bank law trumps state appraisal laws.

FIRREA explicitly states otherwise WRT the appraisals they use for RRTs and FRTs.

Besides all that - this entire tangent has nothing to do with what TAF does. These are all decisions being made under the law by the govt agencies, as is their right. If there's a dispute between the states and the feds that's between them. TAF has nothing to do with it.

 

[Terrel L. Shields]

OK mea culpa, joined the thread late. Any review performed by an independent fee appraiser should comply. But when not licensed in that state what can a board do but send a "cease and desist" letter. As for bank in house appraisers, our state supposedly had to add this section over federal bank law:

(2) The Arkansas Appraiser Licensing and Certification Act, §17-14-101 et seq., §17-14-201 et seq.,
and §17-14-301 et seq., does not apply to:
(A) Persons performing appraisals as officers or staff of a bank, savings and loan, or credit union;
(B) Company foresters in the ordinary course of their duties; or
(C) Staff appraisers performing ad valorem tax appraisals for county assessors or employees of
contractors performing county-wide reappraisals

 

[Joyce Potts]

Again, the original post had to do with an independent fee appraiser they hired just like the hired me to do the original appraisal.

 

[George Hatch]

OK mea culpa, joined the thread late. Any review performed by an independent fee appraiser should comply. But when not licensed in that state why can a board do but send a "cease and desist" letter. As for bank in house appraisers, our state supposedly had to add this section over federal bank law:

(2) The Arkansas Appraiser Licensing and Certification Act, §17-14-101 et seq., §17-14-201 et seq.,
and §17-14-301 et seq., does not apply to:
(A) Persons performing appraisals as officers or staff of a bank, savings and loan, or credit union;
(B) Company foresters in the ordinary course of their duties; or
(C) Staff appraisers performing ad valorem tax appraisals for county assessors or employees of
contractors performing county-wide reappraisals

I don't know why "A" would be a thing, unless the AR regs were using atypical definitions or perhaps had some other quirk going.

 

[Terrel L. Shields]

M

I don't know why "A" would be a thing, unless the AR regs were using atypical definitions or perhaps had some other quirk going.

Missouri
5. The provisions of sections 339.500 to 339.549 shall not be construed to require a license or certificate for:

  (1) Any person, partnership, association or corporation who, as owner, performs appraisals of property owned by such person, partnership, association or corporation;

  (2) Any licensed real estate broker or salesperson who prepares a comparative market analysis or a broker price opinion;

  (3) Any employee of a local, state or federal agency who performs appraisal services within the scope of his or her employment; except that, this exemption shall not apply where any local, state or federal agency requires an employee to be registered, licensed or certified to perform appraisal services;

  (4) Any employee of a federal or state-regulated lending agency or institution;

  (5) Any agent of a federal or state-regulated lending agency or institution in a county of third or fourth classification.