Where Do You Think "geographic Competency" Begins And Ends?

[Eli]

 

[DWiley]

I would like to make a request for a cease fire. This is an important topic, and I for one am finding the relevant commentary very thought provoking. So, I don't want the thread shut down because of the ad hominem.

GH said that he has no one on ignore. I took that same high road approach for many years, but given the lines that were crossed after the shooting in Vegas, I finally decided to put a select few participants on ignore, and that has been very good for my blood pressure YMMV

 

[George Hatch]

Anyone who is concerned about me getting torqued on the personal level should let that go. I can and will stick up for myself if something bothers me. The only kind of accusation that annoys me is an allegation of dishonesty. I've been stupid before and that's not so bad. I'd much rather be called stupid than dishonest.

 

[J Grant]

DWiley, ]Given the decisions that some state boards have made, you really can't see the potential problem??

Some states tried to make exterior only appraisals illegal, so why would one not expect the same for hybrids? Suppose a state board decided that it didn't like desktop or hybrid work, and to curtail that work the board passed a rule saying that one had to have personally visited an area within the past X months in order to proclaim geo competency.

I'd be fine if state boards decide to curtail hybrids ..(jmo) but .the example about states making exterior illegal never came to pass because they could not, since exterior appraisals are performed by appraisers, and thus USPAP compliant. However hybrids are a different animal with non licensed people ( the inspector) doing a significant part of the appraisal .Whether that is your fear about state boards and hybrids or something else, I can't know.

I can not see how state boards could legally pass a rule an appraiser has to have personally visited an area within X months to proclaim geo competency ( especially since competency is USPAP, not geo competency? ) I believe such speculation is a straw man to get appraisers frightened of any possible board actions about geo competency and hybrids....hybrids have been used far as I know for REO work/servicing, perhaps their expansion into Fannie or origination work involving consumers brings a different spotlight on them with boards? Or what is the concern about them?,

Or, suppose they said one had to have appraised a property in the area within the past X months in order to proclaim geo competency.

Why would boards do that, and what would give them authority if they did? I think it is fear mongering boards have certain powers but certainly enormous limitations.


Or, suppose they followed what some lenders have done and said that the appraiser had to live/work within X miles in order to claim geo competency. If you think that is far fetched, just do a little research on how some state boards reacted when the 2055 was introduced

Again, why would boards have the standing to do that or enforce it? - lenders /clients can make assignment conditions or set up conditions for hiring an appraiser such as must have 5 years experience or geo familiarity I fail to see how boards can do that.

Those ideas might sound good to some in this thread, but those same rules would also have to apply to all work - including "regular" lender work and private work. And, keep in mind that Fannie doesn't allow one to gain competency during the assignment, so a state adopted rule proclaiming what it took to be geo competent could have a huge impact on Fannie work. Do you want to be sitting in front of your state board because you did an appraisal in an area that you know but have not done work in for the past year?

It is preposterous to think state boards would or could enact these rules especially as they have no standing to do so - but they can find and enforce USPAP violations or license violations
,
You asked - How can one have geo competency if one has not been to the area before? That is all well and good until you find yourself in a new area, because then you have to answer the same question

That question has been asked and answered here, clearly there are ways an appraiser can take to competently appraise in an an area unfamiliar to them- which still might not make them "geo competent" as far a depth of experience in that area, but there are assignment specific steps they can take to complete assignment.

The risks to regular work is far greater than the risk to existing hybrid work,

The reverse is true imo

because most who use hybrids now have zero problem whatsoever with an appraiser indicating that he/she gained the necessary competency during the assignment (as allowed by USPAP, but not by Fannie)

I have no idea what the threat about hybrids is ( if any) perhaps because now they are used for servicing but in future for origination appraisals ( fannie), or widely expand ther geo areas or have out of state appraisers doing the desk part? I don't know, but whatever issue might be , I see no indication of boards suddenly getting new powers about traditional work

All I see is your putting forth speculation ...Boards can enforce USPAP, they can't invent new rules abut practice even if they tried in past obviously they failed. They can enforce licensing laws and perhaps intervene in matters of threat to public trust , if any of that intersects with hybrids and non licensed inspectors now doing appraisal practice I have no idea. Something is spooking you about state boards and rolling out hybirds for fannie work?

The questions I posed need to be answered, because everyone involved (users and appraisers) needs to know the correct application of the rules. - but the answers need to be based on the fundamentals, not knee jerk reactions.

Answers to what? Some far fetched speculation about some far fetched and not possible to enact or enforce legally board forays into geo comptence within their own state? If an appraiser is licensed within a state I fail to see how a state board can possibly interfere with that, unless a report done by out of area generated a complaint stemming from competence traced back to not knowing the area and thus producing a misleading report or series of errors .. ( USPAP violations)

There must be some threat though to hybrids involving non appraisers with no licensing doing appraisal work from boards and accompanying appraise at a desk relying on it, or out of state desktop done or some other thing spooking you about state boards and hybrids, but as I am not a fan of the idea of hybrids, it does not concern me - and the attempt to say if they make a ruling about hybrids it can mean it affects traditional practice that licensed appraisers do within their own state is far fetched fear mongering- my point of view, people can make their own conclusions.

Though we disagree at times I very much appreciate your participation here, as I do with others I disagree with...I wish people would stop throwing important topics off course with bickering and personal insults ( whoever they are)

 

[George Hatch]

I don't think anyone should let themselves get too nervous about all or even most of the assignments migrating to the less comprehensive SOWs. We've always had the 2055 and yet most users haven't preferred those over the 1004. They only consider the 2055 for certain situations, so that's probably the product these desktops will cut into, not the 1004s.

As with the 2055 there will be a lot of assignments that will be immediately obvious to most appraisers to be unsuited for anything less than the full monty. I'm sure some appraisers will act more agressively than others when it comes to deciding which they think they can do and which they'll want to recommend for personal inspection.

 

[DWiley]

DWiley, ]Given the decisions that some state boards have made, you really can't see the potential problem??

Some states tried to make exterior only appraisals illegal, so why would one not expect the same for hybrids? Suppose a state board decided that it didn't like desktop or hybrid work, and to curtail that work the board passed a rule saying that one had to have personally visited an area within the past X months in order to proclaim geo competency.

I'd be fine if state boards decide to curtail hybrids ..(jmo) but .the example about states making exterior illegal never came to pass because they could not, since exterior appraisals are performed by appraisers, and thus USPAP compliant. However hybrids are a different animal with non licensed people ( the inspector) doing a significant part of the appraisal .Whether that is your fear about state boards and hybrids or something else, I can't know

I can not see how state boards could legally pass a rule an appraiser has to have personally visited an area within X months to proclaim geo competency ( especially since competency is USPAP, not geo competency? ) I believe such speculation is a straw man to get appraisers frightened of any possible board actions about geo competency, when the only place place a board would get involved with it might be across state lines license jurisdiction or responding to complaints or possibly they might take issue with non appraisers doing a a significant amount of appraisal practice ( the inspection part of an appraisal). I can't see other grounds for boards getting involved with this or why they would ?

Or, suppose they said one had to have appraised a property in the area within the past X months in order to proclaim geo competency.

Why would boards do that, and what would give them authority if they did? I think it is fear mongering boards have certain powers but certainly enormous limitations.


Or, suppose they followed what some lenders have done and said that the appraiser had to live/work within X miles in order to claim geo competency. If you think that is far fetched, just do a little research on how some state boards reacted when the 2055 was introduced

Again, why in the world would or could they boards have the standing to do that or enforce it? - lenders /clients can make assignment conditions or set up conditions for hiring an appraiser such as must have 5 years experience or geo familiarity I fail to see how boards can do that.

Those ideas might sound good to some in this thread, but those same rules would also have to apply to all work - including "regular" lender work and private work. And, keep in mind that Fannie doesn't allow one to gain competency during the assignment, so a state adopted rule proclaiming what it took to be geo competent could have a huge impact on Fannie work. Do you want to be sitting in front of your state board because you did an appraisal in an area that you know but have not done work in for the past year?

It is preposterous to think state boards would or could enact these rules especially as they have no standing to do so - but they can find and enforce USPAP violations or people practicing without a license. There must be some speficif concern about boards and hybrids, however, hybrids do have non licensed appraisers doing a signficant portion of appraisal work . If it is a different fear about boards and hybrids please explain, I cant' know what it is. But I fail to buy it that if a board makes a ruling about hybrids it will extend to/threaten traditional appraisals.

You asked - How can one have geo competency if one has not been to the area before? That is all well and good until you find yourself in a new area, because then you have to answer the same question

That question has been asked and answered here, clearly there are ways an appraiser can take to competently appraise in an an area unfamiliar to them- which still might not make them "geo competent" as far a depth of experience in that area, but there are assignment specific steps they can take to complete assignment.

The risks to regular work is far greater than the risk to existing hybrid work,

The reverse is true imo

because most who use hybrids now have zero problem whatsoever with an appraiser indicating that he/she gained the necessary competency during the assignment (as allowed by USPAP, but not by Fannie)

I have no idea what the threat about hybrids is ( if any) perhaps because now they are used for servicing but in future for origination appraisals ( fannie), or widely expand ther geo areas or have out of state appraisers doing the desk part? I don't know, but whatever issue might be , I see no indication of boards suddenly getting new powers about traditional work

All I see is your putting forth speculation ...Boards can enforce USPAP, they can't invent new rules abut practice even if they tried in past obviously they failed. They can enforce licensing laws and perhaps intervene in matters of threat to public trust , if any of that intersects with hybrids and non licensed inspectors now doing appraisal practice I have no idea. Something is spooking you about state boards and rolling out hybirds for fannie work?

The questions I posed need to be answered, because everyone involved (users and appraisers) needs to know the correct application of the rules. - but the answers need to be based on the fundamentals, not knee jerk reactions.

Answers to what? Some far fetched speculation about some far fetched and not possible to enact or enforce legally board forays into geo comptence within their own state? If an appraiser is licensed within a state I fail to see how a state board can possibly interfere with that, unless a report done by out of area generated a complaint stemming from competence traced back to not knowing the area and thus producing a misleading report or series of errors .. ( USPAP violations)

There must be some threat though to hybrids involving non appraisers with no licensing doing appraisal work from boards and accompanying appraise at a desk relying on it, or out of state desktop done or some other thing spooking you about state boards and hybrids, but as I am not a fan of the idea of hybrids, it does not concern me - and the attempt to say if they make a ruling about hybrids it can mean it affects traditional practice that licensed appraisers do within their own state is far fetched fear mongering- my point of view, people can make their own conclusions.

Though we disagree at times I very much appreciate your participation here, as I do with others I disagree with...I wish people would stop throwing important topics off course with bickering and personal insults ( whoever they are)

All I can say is that if you honestly think that state boards are not capable of proposing and passing rules like that, the you have not followed state board actions. Those hypothetical rules I tossed out are quiet tame when compared to some of the proposals that we have seen. And please don't pretend to not understand why they would pass such rules - they would pass such rules to fight the loss of 1004 work - and not even think about the potential harm to that same 1004 work.

Did you notice that the ASB issued some Q&As recently on the topic of hybrids? Did you happen to notice that one of those Q&As was immediately retracted (because the authors didn't think through how the answer provided would affect regular practice)? While you see what I am describing as far fetched, the reality is it is already happening. Keep your head in the sand if you wish. I am out.

 

[J Grant]

All I can say is that if you honestly think that state boards are not capable of proposing and passing rules like that, the you have not followed state board actions. Those hypothetical rules I tossed out are quiet tame when compared to some of the proposals that we have seen. And please don't pretend to not understand why they would pass such rules - they would pass such rules to fight the loss of 1004 work - and not even think about the potential harm to that same 1004 work.

Cry me a river- if a state board has the guts to make a rule to fight the loss of 1004 work, I doubt it would harm that same 1004 work ( but it could harm/curtail the use of hybrids)

Did you notice that the ASB issued some Q&As recently on the topic of hybrids? Did you happen to notice that one of those Q&As was immediately retracted (because the authors didn't think through how the answer provided would affect regular practice)? While you see what I am describing as far fetched, the reality is it is already happening. Keep your head in the sand if you wish. I am out.

Looks like your concern is about hybrids; there is no proof that if a state board makes a ruling about hybrids, with it's element of non appraiser participation ( the inspector), that the ruling could apply to traditional appraisals.

However, if and when anything changes at a state board appraisers can deal with it then, and -no guarantee a change would be positive or negative for appraisers . I personally don't buy the premise that a state board rule curtailing hybrids would adversely affect traditional appraisals, but rather the reverse is likely, that a state board ruling curtailing hybrids would help traditional appraisals.

 

[Artemis Fowl]

... and I personally do not believe serersnerI doubt itt at f bl...

Woah. You okay there? Cat being helpful?

 

[timd354]

All I can say is that if you honestly think that state boards are not capable of proposing and passing rules like that, the you have not followed state board actions. Those hypothetical rules I tossed out are quiet tame when compared to some of the proposals that we have seen. And please don't pretend to not understand why they would pass such rules - they would pass such rules to fight the loss of 1004 work - and not even think about the potential harm to that same 1004 work.

There is no doubt that some people on some state boards use their role on the those boards to try protect the business interests of appraisers (and themselves in some cases) as opposed trying to protect the public trust or objectively enforcing USPAP and applicable laws and regulations.

Anyone who thinks otherwise is terribly naive.

 

[DWiley]

Again, your concern comes from hybrids, and frankly, imo if state boards curtail hybrids it would help traditional appraisals, because there is not a correlation that just because a state board makes a ruling about hybrids, which has a particular element of non appraiser participation ( the inspector), there is no grounds to believe such a ruling could expand to traditional appraisals where it is the appraiser doing both. (, whether the ruling be about geo competence or other issue regarding hybrids..)
.

I would be very interested in how it is you think a board could adopt rules related to application of the COMPETENCY RULE and have them apply to only one type of work.

BTW, protecting work is NOT the role of a state regulatory board. Asks the dentist how that kind of action worked out for them with the FTC.