Discussing Regulation that Affects Appraisers

Friday, October 25, 2013

There are a few things that let you know that summer is officially over every year. The leaves begin to change color, there is a slight chill in the air, pumpkins are placed on doorsteps, and the Association of Appraiser Regulatory Officials (AARO) holds their Fall Conference in Washington D.C. I was lucky enough to head to D.C. and participate in the conference again this year. It was a great chance to hear about the upcoming changes that are sure to change the appraisal industry.

The Appraisal Buzz asked me to share some of the highlights with its readers to they can be kept up to date with the latest news and regulation that will affect appraisers. While there were many quality speakers and panels over the 4 day conference I wanted to point out some of the hot button issues that created the most buzz.

Defining AMCs and Appraisal Portals

Technology advancements in the appraisal industry have caused a drastic need to define companies by the products and services they offer. There was a huge amount of discussion on how to define portals, AMCs, and Third Party Appraisal Companies. Since the definitions of AMCs vary widely from state to state, an AMC in one state may not necessarily be an AMC elsewhere. As the definition of what an AMC is continues to grow, it seems likely that more portals will be required to register to remain compliant with certain state laws.

Supervisor/Trainee Partnerships

A great deal of thought was given to discussion of how best to improve the trainee process. Each panelist spoke passionately about the need to act now to help improve the process for all since any real change could take years to accomplish. With new applicants now having to obtain a college degree and log a large number of experience credit hours, will attrition cause harm to the appraisal profession? When asked for comment, Greg Stephens, Chief Appraiser and SVP Compliance for Metro West replied, "Do College graduates have more appealing options than having to work at least two additional years before qualifying for a license that gets them into the entry level of the profession, with no alternative or fast-track competency equivalent?" I think we all know the answer to Greg's question. It's obvious that barriers to entry are cutting off the supply of new blood into the appraisal industry.

Background Check Policies

Beginning January 1, 2015, the Appraiser Qualifications Board of the Appraisal Foundation changes to the Real Property Appraiser Qualifications Criteria will take effect. At that point, all candidates for a real property appraiser credential will be required to have a background check performed. With that in mind, discussion was focused on FBI background checks, fingerprinting and deciding what other information should be verified as well. Joan Trice, Founder and CEO of Clearbox, spoke on the opening day of the conference. She had this to say about the upcoming regulations and requirements, "The Appraisal Foundation's mission is to preserve the public trust. The Appraisal Qualifications Board's Criminal background check requirements will go a long way to achieving that goal. At present there is not a lot of confidence in the appraisal process, in appraisal reports or in the appraisal community. That is a sad reality. Ensuring that the appraisal community are professionals of the highest ethical and moral standing is a great starting point."

Some of the after hour discussion focused on what weight should be given to background checks, how many years should they cover and the "rehabilitation" process and what it should entail. My question for each of you is, if someone knowingly commits appraisal fraud and is convicted, should they ever be allowed to be an appraiser again? Do you believe there are crimes that are so heinous that anyone convicted should be automatically disqualified? Appraisers perform such an important job for the housing industry. Are we willing to accept the risk that someone who committed fraud won't do it again?

Surety Bonds and Recovery Funds

With close to half of all states requiring AMCs to purchase surety bonds and separate bonds being required for each state, the cost for an AMC being registered nationally can be extremely prohibitive. But do these measures even protect the appraiser if an AMC closes? Discussion of recovery funds, which can offer additional protection, and the costs and benefits offered additional insight. One panelist suggested that perhaps a national recovery fund might be a better alternative, but which is best? For more information on Surety Bonds, CLICK HERE

The best way to figure out solutions for these issues would be to be to stay informed and bring the discussion to the forefront. Transparency in these topics increases the effectiveness of the state regulation and decision making. Appraisers should check in with their state boards and learn more about the laws that will affect their business. Let your voice be heard. Tell us what changes you think should be made in the industry.

Have any comments or would you like to submit content of your own? Email comments@appraisalbuzz.com.

Comments

In regard to Kevin Hopkins Appraisal Buzz article about the AARO conference:

First, thanks for the update!

Secondly, in regard to the Surety Bonds – but actually more concerning appraisers themselves:

I constantly read about and hear from appraisers that XYZ AMC company ‘owes me several hundred or thousands of dollars’ in unpaid appraisal fees. Well, really, whose fault is that?

Far too many appraisers don’t monitor their account receivables (i.e., fees owed) until it’s too late. My suspicion is many appraisers have not been well trained in business management. They just blindly accept every new assignment without knowing whether or not that client owes them for previously completed assignments. Working for free is no way to operate an appraisal business.

Appraisers have got to be trained and taught to be more careful. They need to establish operating policies that maintain their cash flow properly. Appraisers can’t be afraid to decline one or more assignment if that client owes them money that is past due beyond a reasonable time period … such as 45 days after report submittal.

Another aspect: some of the state AMC licensing laws have provisions for appraiser payment within a specified time period. The appraiser needs to know what that is, and the appraiser should discuss the law with their client when payments get stretched out too far. If your state has an AMC licensing law without that provision, then get with your Appraiser Coalition or individual legislator and have wording inserted in the law as an amendment.

And with the Surety Bonds required: some states do not allow the appraiser to ‘attach’ the bond if an AMC does not pay the appraiser. Other states, like Washington, allow the appraiser to contact the bonding insurance company to make a formal complaint and ask for payment of the fee(s) from the bond amount. And the Washington bond amount has been increased this past legislative session to $100,000, from the former $25,000, as a way to better protect appraisers.

Dave Towne, AGA, MAA
Certified Residential RE Appraiser
12+ yrs Experience
FHA Approved
Accredited Green Appraiser
360-708-1196
towneappraisals@clearwire.net
www.towneappraisals.com
Mount Vernon, WA

Appraisal Institute – Practicing Affiliate Member
National Association of Appraisers – Member
Appraisers’ Coalition of Washington - Member

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