ASC notice to state regulators:
Excerpt: The Hotline will begin operation no later than March 29,2013. The Hotline will refer complainants to appropriate State and/or Federal agencies to handlecomplaints of alleged violations of the Uniform Standards of Professional Appraisal Practice(USPAP) and/or appraisal independence requirements. The Hotline will direct complainants tocontact you to formally file their complaint using the existing protocols established by your State.The Hotline does not initiate complaints, act on behalf of complainants, arbitrate complaints, assistin appealing the outcome of complaints, or follow up on complaint referrals previously provided
Link to full notice:
http://www.scribd.com/doc/126820613/ASC-Appraisal-Complaint-National-Hotline-Notice-to-States
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Feb 4, ASA/NAIFA sends letter to ASC asking for delay
Excerpts of a few bullet points:
– The ASC designed the appraisal complaint hotline system behind closed doors, and has failed to allow stakeholders to comment on it prior to final implementation:
– The ASC’s hotline system, as proposed, violates congressional intent and the clear language of the dodd-frank provision authorizing it:
– Congress intended the hotline to provide appraisers with an ability to report efforts to undermine their independence, not as a catch-all mechanism to be used against appraisers by persons disgruntled because the appraised value did not meet their needs or for other non-specific or Non-serious reasons:
Link to letter http://c.ymcdn.com/sites/www.naifa.com/resource/resmgr/legislation/02.07.2013_letter_from_asa_a.pdf
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Feb 12, AI/ASFMRA sends letter to ASC asking for delay
Excerpt:
However, in speaking with state appraiser regulatory officials, practicing appraisers and others involved with real estate and mortgage finance, virtually no understanding of the hotline and its intended purpose, as well as the proposed protocol, exists. As such, we believe that the protocol could be met with unnecessary trepidation simply because to date the ASC did not seek stakeholder input. As such, we respectfully request that the ASC refrain from approving the protocol, and instead release the protocol for public comment, similar to the process used by the ASC in drafting Policy Statements. Since the hotline likely will impact other mortgage and real estate professionals and regulatory agencies, we believe that all stakeholders deserve to have an opportunity to review comment on the hotline before it is operational. This is the foundation of good government and, in this case, we believe that such a measure actually will engender support for the proposed protocol.
Link to AI/ASFMRA letter
http://www.appraisalinstitute.org/newsadvocacy/downloads/ltrs_tstmny/2013/AI-ASFMRA-to-ASC-on-Hotline.pdf
My comments: The ASC was mandated by law to set this up. I have not read all these links, so I have no opinion. It is all up to you!!
My opinion still is: This is a good thing on many levels, none the least of which is more transparency and accountability being required of appraisers.
My gratitude to the ASC for understanding that the complaint process about appraisers as well as by appraisers needed attention. All an appraiser needs to do is to develop the reports so that they are defensible. If you can’t do that then don’t complete the assignment.
We are still working on that public trust issue folks, and given the nature of what we do, credibility is all we really have going for us. The days of making value to make clients happy is over and hopefully gone forever.
Nobody likes to answer formal allegations, which I assume is what the “hotline” is inteded to produce, but when I get right down to it, what changed? It is just a referral to the existing State agencies, and now appraisers can use it too. It seems that whomever the cmplainant is has to do most of the investigation and research needed to support the allegations, which is a real pain. I guess I’m concerned with whether our State atency can afford any increase in complaints
I
Assessed value does not determine mkraet value. However, you should be aware that in many locations the property is reassessed upon sale, so the assessed value (and thus, taxes) could increase from what they are now.
The ASC was mandated by Dude-Fink to create a hot line for APPRAISERS to report attempts to pressure them by Lenders, Agents, Builders and such “interested” parties. The states already have an adequate system for handling complaints AGAINST appraisers.
Of course the complaint will be “my appraisal was too low”. Will we be forced to answer these type of complaints???
I agree with Landlord, dont worry about it. It is actually a good thing to have a lower conuty appraisal it is what the conuty uses to set property tax costs but has no true way of assessing the property for sale values. Sales values are a supply and demand thing.
Creating any entity without the parties involved allowing their input is illegal, or should be if it isnt! If the Appraisal Institute will create a petition, I will sign it, and I am SURE many more within our industry will too. There is power in numbers. Who is willing to put this together?