Daily Archives: November 1, 2016
ICAP Attended The 2016 Meeting of the Network of State Appraiser Organizations
October 20, 2016
The Network of State Appraiser Organizations, which connects independent appraiser coalitions across 23 States, recently met at the National Association of Realtors (NAR) Washington, D.C. offices. Representative volunteers from nine state coalitions were in attendance. Illinois Coalition of Appraisal Professionals (ICAP) member Karen Emerle, SRA, the current ICAP Executive Board Secretary, attended the meeting. The purpose was to discuss a variety of topics affecting the appraisal profession. Invited speakers included AARO President Anne Petit, AARO President-Elect Debra Rudd, Appraisal Subcommittee (ASC) Executive Director Jim Park, ASC General Counsel Alice Ritter, and Sehar Siddiqi, NARs Regulatory Policy Representative. A special thank you to NAR for their generosity in providing a conference room for the day.
The topics discussed with Anne Petit and Debra Rudd centered around the relationship between AARO and appraiser coalitions. The Network inquired about the status of AARO’s professional organization project, trainee issues, AMC and state selective enforcement issues, and the potential to bring together AMCs, regulators, and appraisers to develop a best practices white paper. President Petit said AARO has a dual responsibility to educate and help protect consumers while not being over-burdensome to the licensees. It is important to find the sweet spot between the two. Additionally, the licensees should be treated with respect. The aim is to be instructive, utilizing a more compliance driven rather than a punitive model. Courtesy should be given to all stakeholders informing them, at the same time, of development or implementation protocol activities. President Petit requested input regarding any topic for discussion or speakers the appraiser coalitions would like to see included at future AARO conferences. The Spring AARO Conference is scheduled for April 7-9, 2017 in Tampa, Florida.
Executive Director Park provided a synopsis pertaining to the ASC. Its authority and functions started in 1989 with the Savings & Loan crisis. The Appraisal Foundation already existed and was given authority involving the private sector and State and Federal governments. One must be on the national registry to perform federal regulated transactions (FRTs). Dodd Frank gives them additional authority and responsibility, especially over AMCs and the registration fees. General Counsel Ritter drafted the AMC rule which was released for comments. Of the 103 comments received, the vast majority of appraisers did not want the AMC fee to be passed onto appraisers. The ASC does not have the authority to enact this restriction. The ASC is now working on the final rule. The question of whether State Boards are able to enforce their State rules was broached. Included in Dodd Frank is a provision whereby States might receive grant funds. In 2008 1.6 million dollars of grants were issued. Conversely, in 2015 only $350,000 grant funds were disbursed. Implementation of the AMC restriction takes effect August 18, 2018. This prevents AMCs from providing their services for any FRTs in a State that does not have an AMC program in place. The national registry serves the purpose of identifying who is an AMC. Currently, the AMC appraiser registry fee is $25. The Interagency Guidelines provides the definition for panel. The AMC must pay a fee for each appraiser listed on every panel in every state the AMC is registered in. It is not a requirement States have an AMC program. Fannie and Freddie are not FRT’s. Zach Dawson, the Director of Collateral Policy and Strategy for Fannie Mae, has said that Fannie Mae does allow the use of appraisal trainees with appropriate supervision and does not require the supervisor to inspect. This has always been Fannie’s policy. The ASC has State oversight of both AMCs and appraisers, and compliance reviews on each profession will be conducted separately. The AQB has the authority to set minimum qualification standards. The ASC has no authority to over-rule the AQB minimum qualification criteria. Executive Director Park was asked about what issues will be affecting fee appraisers in the future. The list includes the loss of control of market data and the efforts being exerted to replace appraisals with evaluations. The ASC is working with lenders and regulators to figure out what the future between lenders and appraisers will be.
The final guest speaker, NAR Policy Representative Siddiqi, involved a discussion around appraisal issues the NAR membership is experiencing, various NAR committees and their focus on appraisal, BPO, and CMA policy recommendations. A recent change in policy requires anyone serving 15 years or more on a NAR committee must take a break from service. Policy Representative Siddiqi outlined recent issues NAR has responded to with some type of NAR action taken. They include the recent FHA guideline changes, appraiser shortage, pass-down of fees, and completed appraisal delivery time frames. NARs response to the FHA guideline change resulted in FHA making a change to the newly enacted guideline. NAR is developing a survey relative to the perceived appraisal shortage. The goal of the study is to quantify it, and is being pursued through a relationship between CoreLogic and the AMCs. NARs stand on AMCs is the AMC should be properly regulated, their registry fees should not be passed on to the appraiser and/or the consumer, and an appraiser should not be precluded from the AMC registry list. Due to the length of time to get a completed appraisal, the MLS data is licensed to Corelogic who created a program which was sold to the Veteran=s Association. The NAR appraisal summit was/is a closed summit mostly for Federal Regulatory Advisors on Appraisers, bankers, and the ASC. The next NAR Annual Conference is scheduled for November 4-7, 2016 in Orlando, Florida. The Saturday, November 5, 2016 afternoon topic is: Real Property Valuation Forum: The Wide World of AVM Values. Scheduled time is 1:30 PM to 3:00 PM. Policy Representative Siddiqi can be reached at 202-383-1176 or firstname.lastname@example.org.
ICAP continues to work on behalf of and for all their members. Participating in The Network provides ICAP members the opportunity to stay abreast of issues affecting the appraisal profession nationwide.