Evaluations and Jurisdiction

Sunday, January 19, 2014

Post No. 37 – Back in November, I posted my letter to the North Carolina Chapter of The Appraisal Institute asking them to work on getting a law passed to allow their appraisers to perform non-USPAP Evaluations. As a follow up, I was able to obtain a letter from the North Carolina Appraisal Board to an out-of-state Evaluator. The main excerpt is as follows:

"The specific allegation is that you appraised a property in North Carolina while not being licensed by the North Carolina Appraisal Board to do so. In addition, the appraisal did not meet USPAP reporting requirements. Please note that North Carolina law defines an appraisal as 'an analysis, opinion, or conclusion to the value of identified real estate or specified interests therein performed for compensation or other valuable consideration.' This definition is broader than that in USPAP. Although you titled the valuation product as an evaluation and stated it was not an appraisal, it does meet the definition of appraisal in this state and will be treated as such.

In accordance with our Disciplinary Policy, you may respond to any allegations made. Please note that your response must be in writing and made within thirty days of your receipt of this notification."

The major issue I see is jurisdictional. Let's assume this Evaluator is in Arizona or whatever state you want to use outside of North Carolina. Some questions might be as follows:

1. The Evaluator never stepped foot in North Carolina. What right does the NCAB have to tell someone in Arizona what they can or cannot do?
2. The Evaluation was not transmitted via email or snail mail to a NC bank. What right does the NCAB have to deem any item or service outside of the state as being illegal?

Lawyers can come up with many other issues that question the NCAB's authority in this matter. We won't get into Federal Law saying the service is permitted by licensed appraisers and non-licensed individuals.

My suggestion is that instead of wasting resources trying to go after these out-of-state individuals, why not get a law passed to allow your licensed in-state appraisers to perform non-USPAP Evaluations? Just like Georgia and Tennessee have done. Pass such a law and it is doubtful banks will use out-of-state individuals as much. Most banks prefer to use local appraisers.

I obviously don't know how these situations will be resolved or what the Evaluators will do. I would assume the best course of action would be to simply ignore the NCAB letter as they have no authority over anyone outside of North Carolina.

Let's open this huge world of work to appraisers once and for all.

Ban the Sales Comparison Approach!

George R. Mann, CRE, FRICS, MAI


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