This is One Reason Why I DON'T .....

Wednesday, June 4, 2014

This is one reason why I DON'T put a FULL SIZE copy of my appraiser license, and E&O Binder page in reports, despite what some clients request. I just tell 'em NOPE, won't do that - because those have nothing at all to do with the loan underwriting.

Appraiser License info is already in every report .... (form reports, at least) so the client does not need to see a replica (which can be forged), and if they want to sue me, they can send me something in writing because my address is also in every report. Likewise with your info .... so quit including a FULL SIZE license and E&O binder in reports! (Clients are given this info separately, outside of any report. I have no problem with that.)

Also remember this: AMC's are required to 'vet' their appraisers in advance, so they should already have those documents. There is no valid reason for an appraiser to include them in a report when an assignment comes from an AMC. But, read about the court case below that happened recently in Conneticut, for a valid reason NOT to include it.

U.S. Attorney's Office March 19, 2014 District of Connecticut

Deirdre M. Daly, United States Attorney for the District of Connecticut, announced that Brandy Gomez, 35, of East Hampton, pleaded guilty today before U.S. District Judge Alvin W. Thompson in Hartford to one count of conspiracy to commit mail and bank fraud related to a real estate appraisal scheme.

According to court documents and statements made in court, Gomez was a provisional licensed appraiser in Connecticut. Under Connecticut's real estate appraisal regulations, Gomez was required to be supervised by a certified appraiser. Between 2006 and 2008, Gomez conspired with another individual to obtain real estate appraisal fees to which they were not entitled.

As part of the scheme, Gomez's co-conspirator obtained the names, certified appraiser numbers, appraiser certificates, business names and addresses, and electronic signatures of certified appraisers and, without the certified appraisers' knowledge, used this information when submitting real estate appraisals that Gomez had purportedly completed to mortgage brokers and lenders. Gomez deposited fraudulently obtained appraisal fees into her personal bank account and shared them with her co-conspirator.

Gomez and her co-conspirator also submitted falsified work logs to the Connecticut Department of Consumer Protection purporting to show that Gomez completed dozens of real estate appraisals under the supervision of a certified appraiser when, in fact, she had not performed such work and was not entitled to the appraisal fees.

Gomez and her co-conspirator received approximately $47,908 as a result of submitting the unauthorized and fraudulent appraisals.

Judge Thompson scheduled sentencing for June 20, 2014, at which time Gomez faces a maximum term of imprisonment of 30 years.

This case is being investigated by the Federal Bureau of Investigation, the U.S. Department of Housing and Urban Development-Office of Inspector General, the Internal Revenue Service-Criminal Investigation Division and the U.S. Postal Inspection Service. The case is being prosecuted by Assistant U.S. Attorneys David T. Huang and Paul H. McConnell.

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

Comments

If we all agreed not to provide license copies in reports, how would the Gomez story be any different? Certified appraiser numbers are public knowledge. Electronic signatures can be obtained by anyone. The co-conspirator, presumably an employee of the AMC or lender, could still supply names of approved appraisers, and probably licenses too, from the copy machine. The fraud doesn't depend on a copy of the license, and wouldn't be prevented by withholding them from reports either.

Out of total respect for differing opinions, I would disagree with this stance for the following reasons:

1. To say it has nothing to do with underwriting is to totally misunderstand Federal Law. Federal Law requires a licensed/certified appraiser be used by a lending institution. If this is not the case, then the whole deal is dead right there. So, for a client to ask for a copy of the license has everything to do with underwriting.

2. As I continue to tell appraisers for 22+ years, if it is something I want as a client you better do it - as long as I am not asking to do something illegal. The client decides what goes in an appraisal report, not an appraiser. To be clear both obviously agree all of the content required by USPAP is required AT A MINIMUM. But, the client decides what else they want in a report.

3. In attending lending school offered by the RMA, I will always remember the instructors saying that fraud will happen no matter what we do. People wanting to commit fraud spend 24/7 figuring out ways to do such. We will never stop fraud. Just do your job and protect yourself best you can and let the criminals go get caught.

Lastly, I tell appraisers you have the right to fire clients. So, if you don't like the requirements of a client feel free not to work for them.

I agree with George - mostly. The license issue is largely moot because that information is in the report and is otherwise publicly available. Doctoring up a new "certificate" is a cake-walk for most fraudsters. Appraisers can put a watermark identifying the license as a "COPY" without running afoul of most client requirements.

The E & O issue is a bit more touchy. Putting a copy of my E & O policy into the report is like driving around with a copy of my auto policy taped into the window. Detailing my level of coverage, how much I pay for the policy and my deductible just seems a bit more risky than necessary. Further, it doesn't matter whether or not I have coverage when I do an appraisal, it only matters what coverage I have when I get sued - usually long after the date of the report. Requiring E & O can be a good standard for clients because most of the time, folks who have it will maintain it. There are plenty of ways to demonstrate coverage without pasting the policy in your proverbial windshield. Talk to your client, outline your concern and propose a solution. Or, just bitch about it, but don't expect the same results either way.

Clients can always ask for whatever they want. The appraiser has a business decision to make when those requests conflict with the appraiser's general practice. Just be sure if you are willing to die on some hill that it isn't an anthill.

In response to Mr. Mann's comment: "To say it has nothing to do with underwriting is to totally misunderstand Federal Law. Federal Law requires a licensed/certified appraiser be used by a lending institution. If this is not the case, then the whole deal is dead right there. So, for a client to ask for a copy of the license has everything to do with underwriting."

This is a farcical statement. There is NO federal requirement that we add a copy of our license in reports, because that info from the license is ALREADY in the report. If someone wants to verify the licensed appraiser, just look at page 6 of the pre-printed form, and then compare that info with the state and national registry data bases. A copy of a paper license proves nothing.

An E&O binder page in reports is also not required by federal regulations.

The reason some lenders or 'investors' ask for this un-needed info is because they are lazy and don't really understand how the entire appraisal process works.

Also, if an assignment comes from an AMC (about 60% these days), it's the AMC's responsibility to collect that info if they need it, and it's the lender's responsibility to monitor and manage the AMC agent company they employ to handle appraisal ordering. As I stated in the article, there is no need to add these items to a report just because we're asked to do so. And we appraisers need to learn to stand up to these kinds of requests, explain why, and just say NO.

Mr. Mann is correct: fire the jerk clients who push this so-called requirement. But unfortunately, there are thousands of appraisers who just don't care about acting professionally and will play this stupid game.

I never said it was a requirement of any regulation to place a copy of your license in the report. It is Federal Law that you be appropriately licensed for a federally-related real estate transaction appraisal. The client can be (and MUST be ) sure of that in two ways - check the National Registry or require the appraiser to place a copy in the report. I have been instructing banks of those options for a few decades now. Their choice which way they want to do it. The latter is obviously easier for them, so if I were them (and in some cases I am them), I would make it a standard request.

No wonder the public and clients get so frustrated with the appraisal industry. Appraisers continue to try to dictate the product they provide. That is a fruitless, and to be blunt, stupid concept. Just like any of us as clients who want a house painted or a bathroom remodeled or whatever, we are paying for it and we dictate what we want - the contractor may have to meet certain standards, but we dictate beyond that what we want. Same for appraiser clients. If a client wants the subject photo on page 3, it is not a regulatory requirement, but it is a valid request. Same with a copy of a license....heck if they want a copy of your business card that is valid. To not do it is simply a business decision. I would argue that it is more harmful to tell appraisers not to put their license in a report if a client requests it. That is all. I think it is a valid request and a good business decision to do such. To disagree is fine.

Similar requests that warrant a business decision include 1) Some clients will not accept a limiting condition that limits the appraiser's liability to the appraisal fee (I think that is a good decision by the client, but I never made this a requirement because I knew it was a weightless item and the appraiser would be sued for any amount an attorney wanted to sue for), and 2) Some clients put in an engagement letter that the appraiser cannot appraise the subject property for anyone else for 3 years without approval from the client (probably just a commercial item and not in residential). It is each appraiser's free decision to work for clients with such requirements or not. I like both requirements but never used them personally. The appraiser's I worked with always knew not to appraise for anyone else without talking to us first. Again, not a regulatory requirement - but a client requirement.

Do some work for DOTs and The Yellow Book and so on and see what client requirements really are!!! Heck a copy of your license is a no-brainer in comparison to the extra items required by many clients.

I agree completely with Dave. I am an instructor as well and I have always preached this too. Liability Ins. Administrators actually suggests appraisers not attach their E&O because when the homeowner gets their copy of the report, they feel they can call the E&O years later to sue the appraiser for whatever reason.... Also, your E&O is not readily available to the "crook" and can now be easily forged by someone else if you attach it. The actual paper license is not available to anyone, so attaching it simply makes it easier for the criminal once again. Keep it simple, say no! Per USPAP, it is our job to keep the integrity of our report in check, and that includes passwords and access to your data.

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