Appraisal News and Business Tips

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FHA to require valuing green improvements?

Another great commentary from Dave Towne, the appraiser who keeps up on what is happening!! His comments are below this summary of a letter sent by the Appraisal Institute.

Excerpts from AI comments, contained in their Letter about the proposed letter:

Appraisal Institute Lauds FHA for Green Valuation Proposal
The Appraisal Institute and the American Society of Farm Managers and Rural Appraisers on Sept. 2 lauded the Federal Housing Administration’s proposal to allow appraisers to utilize residual techniques – such as cost and income approaches – to analyze market reaction to green and energy-efficiency improvements in the absence of comparable sales.

Under the draft handbook, appraisers would be required to analyze and report the local market acceptance of special energy-related building components and equipment, including solar energy components, high-energy efficiency housing features and components such as geothermal systems and wind powered components. The draft explains that in the absence of sufficient data to perform a paired sales analysis, the appraiser must consider the cost or income approach to calculate an appropriate adjustment.

AI article
http://www.myappraisalinstitute.org/ano/DisplayArticle/PastIssue/Default.aspx?volume=15&numbr=17/18&id=22399

Direct link to original FHA document:
http://portal.hud.gov/hudportal/documents/huddoc?id=SFH_POLI_APPR_PROP.pdf  See page 68. Dated August 27, 2014.

NOTE: this is proposed, not final. If you read the full document, I could not tell what is existing and what is proposed. The comment period has closed.

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Dave Towne’s email comments, sent to those who subscribe to his emails.

On the surface, this appears to be fair … primarily for the property owner/borrower who has applied for a FHA mortgage loan guarantee.

This appraiser agrees that appraisers who do these kind of assignments must have the appropriate competency, training and experience.  Appraisers are going to have to take specialized ‘green home’ appraising CE courses as one aspect of increasing their knowledge.

But the back end unintended consequence of this proposal is how much in additional fee will the appraiser be allowed to charge for providing an ‘approach’ documentation that is Not Required to be completed by USPAP?  The ‘requirement’ to include a CA or IA becomes an additional assignment condition, added to an already more complicated FHA Scope of Work for FHA assignments.

Secondly, these ‘approaches’ rely on accurate documentation for various component costs and analysis of the income stream resulting from the use of various ‘energy efficient attachments’ to the dwelling … something the average home owner/purchaser/borrower may not have access to or knowledge of.  Yet this proposed REQUIREMENT places the appraiser squarely in the middle of the bulls eye.

Third, adding this level of detail extends the time requirement for report completion.  For these kinds of assignments, a cheap fee and the desire of a “48 hour turn time” after inspection probably won’t be realistic.  Everybody connected to this kind of assignment is going to have to realize that the appraiser will need to be properly compensated and is going to need many more hours or days between assignment acceptance and report submittal … and they are just going to have to live with that reality.  (Appraisers are also going to have to learn to say ‘NO’ and negotiate fees and DD’s when it is appropriate.)

If this just becomes another layer-upon-layer of Scope Creep with no ability to recoup time spent with an appropriate additional fee for the REQUIRED added reporting documentation, then FHA may find itself hurting for appraisers willing to commit to this kind of assignment.  (Re-read the sentence above.)

Dave Towne, AGA, MAA
towneappraisals@clearwire.net
www.towneappraisals.com

My comments: I have never seen any adjustment indicated in my market for energy saving residential improvements except maybe once for a new infill completely “green” home. Of course, I live in the “mild climate” San Francisco Bay Area ;> This has been going on for a long time, without requiring dollar adjustments. The old Fannie Mae URARs had grid adjustment lines for energy efficient improvements.

 

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How to stem appraiser "low tide"

By Alan Hummel, Chief Appraiser Forsythe Appraisal

Excerpt:

The topic may seem peculiar at a time when mortgage originations are down from the heyday of the early 2000s, but if the issue isn’t addressed now, a shortage of qualified residential appraisers could have a dampening effect on the mortgage market at precisely the moment when it is trying to regain its past vibrancy.

The decline in the numbers of appraisers entering the profession can be attributed to many factors including (but not limited to): qualifications and licensing requirements, the economics involved in training, and unwillingness on the part of some financial institutions to allow trainee appraisers to perform services. The most significant obstacle for many trainee appraisers is completing the 2,500 hours of required experience to achieve Certified Residential status, after the education component has been completed.

My comment: The only answer is for lenders to allow trainees to “sign on their own”.Hummel proposes a training program. But, I don’t see this happening on a large scale.  Since Fannie and Freddie started loan securitization in the 1970s, the volume of appraisals needed has been very, very cyclical. Before licensing, most appraisers were employees of lenders. Lenders solved the problem by hiring armies of trainees during boom times and then laying them off when volume dropped. Few appraisers are employees of lenders now. Fee appraisers have been expected to train new appraisers. Lenders paid them a salary and experienced salaried appraisers were the supervisors. But, fee appraisers are not set up for it – no time, minimal supervisor training, little economic incentive, etc.

Read the full article at:
http://www.housingwire.com/articles/31233-how-to-stem-appraiser-low-tide

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$200 appraisal fees – appraisers removed for refusing low fees!!

Blacklisted for Refusing Low Fees
Source: WorkingRE

Excerpt:
Dawson (quoted under an alias because she fears retaliation), tells a story that many appraisers can relate to. She says she was blacklisted for requesting what should be protected under law-her right to customary and reasonable fees. Dawson is different because instead of being secretly blacklisted and left to wonder why she stopped receiving orders after requesting a fee increase on an assignment, she was formally removed from an AMC’s panel after insisting that the AMC’s fee was not customary and reasonable…

Recently, however, her client began using an AMC to manage the appraisal process. After an 18-year relationship with a quality client, Dawson found herself dealing with an AMC that wanted to pay her considerably less than her standard fee. Dawson says the AMC wanted to pay her $290 for an appraisal. “For five years my standard fee with my client was $375. They decide to go through an AMC and now I’m expected to accept a fee of $290 for the same work,” says Dawson.

She discussed her concerns multiple times via telephone with the AMC. “I told them that I would not accept a fee of $290 for the same appraisal that my client had previously paid me $375 for. Their fees are unprofessional and not in the spirit of Dodd-Frank. One girl just laughed at me on the phone because I wouldn’t take $290. She told me they didn’t need me because there are plenty of other appraisers who will do it,” says Dawson.

Dawson was removed from the fee panel for “Unprofessional Conduct – Derogatory responses to communication from Nationwide Appraisal Network,” according to a document supplied to Working RE . Dawson says it was her pushback on fees that led to her removal, which followed her sending the AMC an email pointing out that the C&R fee established between her and her client was $375, and that the fee offered by the AMC was neither customary nor reasonable. The return letter from the AMC concludes: “Due to the issues we have experienced with your conduct… you are hereby notified that you are being removed from our approved appraiser list.”

http://www.workingre.com/blacklisted-refusing-low-fees-2/

My comment: Appraisers are getting letters or emails that they are being removed from AMC lists because they are turning down low fees. I am also hearing about desperate AMCs who can’t find anyone to work for their low fees. This often happens in rural areas with few appraisers. Low fees can be ok in nearby conforming tracts but go rapidly go downhill from there. I have no idea who will be doing appraisals as more and more appraisers are turning down the low fees.

I am also hearing some AMCs are raising fees. Maybe they have figured out that one fee for an entire state often does not work well!!

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$200 Appraisals – Poor Business Decisions for the Appraiser AND Lender
By Joanna Condé
Source Arizona Association of Real Estate Appraisers

Excerpt:
As many of us fight for customary and reasonable fees of $350 or more, some of our appraisal brothers and sisters are still taking the $200 appraisal and not only hurting the cause for the rest of us, but doing something that will eventually, if it hasn’t already, hurt themselves.

… there are many AMCs that pay customary and reasonable fees of $350 and more, that give five business days to do the report, and that will pay more if the properties are complex, in an area that requires more work and research, and will allow more time if there are reasons…

So why would anyone accept a fee below $300, let alone in the $200 range. I can only attribute it to not thinking it through.
Below are the reality checks as I see it.

Reality Check – $: The net from doing one $350 appraisal is about the same or even more than doing two $200 appraisals…

Reality Check – Time: There is twice as much time spent on two appraisals as there is on one. So, the appraiser taking the $200 appraisal spends twice as much time for the same money unless corners are cut. If an appraiser tells me he doesn’t do the same amount of work for the $200 appraisal as he would for the $350, then there is no other choice but to believe he is: a) cutting corners, or b) not doing a full report and providing the information necessary for a credible report, i.e. USPAP compliant. Not smart. The issue becomes not “if” you get reported, but “when” you get reported.

Reality Check – Liability: It seems apparent to me that the same lenders that have the highest foreclosure rates are also the lenders that work through AMCs that pay low appraisal fees and ask for short turn around times…

To Lenders: For those lenders that do not inquire of the AMCs they use what they pay their appraisers, and the time they give them to complete the report, shame on them. They are putting their own company at risk as well the borrower. Why?
The best appraisers won’t work for cut-rate fees. They know the quality of their work and they charge for it. Those appraisers who work for low fees usually produce low quality. “You get what you pay for.”

Low quality appraisals put the lender at a higher risk of making a bad loan.Isn’t it time ALL appraisers and lenders realized that!

Cheap is Expensive!

My comment: well written. Not just a lot of whining and complaining. Explains why it is important to the lender.

CLICK HERE TO READ WHAT OTHER APPRAISERS SAY ABOUT LOW FEES AND POST YOUR COMMENTS ON MY BLOG

Read the full commentary at:
http://appraisersblogs.com/appraisal/the-folly-of-the-200-dollar-appraisal/

 

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Appraiser-AMC symbiosis?? Not!!!

An Evolving Symbiotic Relationship Between AMCs and Appraisers  ????
Monday, August 11, 2014, posted on Appraisal Buzz
Scott Pickell – vice president and chief appraiser at LRES

A few quotes:

“As a former appraiser with nearly 30 years of experience and now an executive working at an AMC, I have observed a true evolution in the way appraisers and AMCs work together. The relationship between AMCs and appraisers started off unsteadily but has improved over the years. It has now reached a point of mutual respect.“

“When working as an appraiser, I recall some AMCs treated me as though I was a rookie in the industry despite my 20 years in the field at the time. There was no reason for that. When AMCs treat appraisers with the respect they deserve, appraisers will return that respect and produce better work.“

My comments: Maybe Pickell’s AMC respects appraisers but the way appraisers are treated by most AMCs does not indicate any respect.

Appraising in the U.S. started during the Great Depression when lenders needed appraisals for foreclosures. Until the 1990s, when mortgage brokers took over, lenders somehow managed their appraisals without armies of telephone calls for updates, 10+ page engagement letters, sending broadcast emails trying to get the lowest fees, etc. etc.

Somehow, since HVCC, appraisers are managed as if they were children, who have to be prodded incessantly and corrected to do their appraisals “right” to ever increasing requirements.

Appraisers are seen as barely competent and unreliable, who have to be heavily managed. But, all of this costs a lot of money, as compared with the old lender management of appraisers. Of course, mortgage broker management cost very little, if anything. Who pays for it today? Appraisers and borrowers.

The same “barely competent” appraisers are increasing required to provide lots of time consuming information and analyses which often do not contribute to the accuracy or reliability of their opinions of value.

Residential appraisers are often required to “support” all their adjustments. That’s fine if you are doing a conforming tract home. If not, it all goes downhill fast. What’s my answer? Turn down as much as possible anything not a conforming tract home. Or, change your geographic area to one that has a lot of tract homes. Working for AMCs with less hassle can help, but scope creep seems to be affecting all lenders.

Few residential appraisers are willing to do non-lender work. Learn how to do it, including marketing. I have special reports that can tell you about how it differs from non-lender work, and how to get work. This will reduce some of your lender dependency. See my ad above.

FYI, I have a Certified General license. I do a lot of 5+ unit apartment properties. They are easier than 2-4 units and I get much, much higher fees. There are few appraisers who do them in my area. Cert residential are not licensed for it and local commercial appraisers don’t like to do them as they prefer commercial and industrial properties.

Very interesting comment posted on an appraiser chat group by Charles Baker, SRA: (editor addition: A more appropriate comment by Pickell would be) “It’s my job to maximize profits for the company. If you wish to participate as a contractor that’s your choice. But make no mistake, our job is to service the client, reduce costs, boost our bottom line and reward our principals and shareholders. You may wish to participate in those profits by contacting our investor relations department, but don’t expect to get rich as an appraiser. Thank you very much.” I really like this comment as it says what a corporate manager would view the situation.

Link to the full article. http://appraisalbuzz.com/buzz/features/an-evolving-symbiotic-relationship-between-amcs-and-appraisers#sthash.QH5TBFby.dpuf

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Fannie looking at adjustment

From AppraisalPort’s monthly newsletter

Author: Steve Costello, who attended the recent Valuation Expo
Excerpts:

“Fannie Mae’s Murphy stated that over the past year, the GSE had been focusing on “quality” and “condition” ratings of comps used in multiple appraisals by the same appraiser and found many cases where the appraiser has changed the quality and/or condition ratings on the same comparable from appraisal to appraisal.  Now, based on the examination of the Uniform Appraisal Dataset (UAD) data, Fannie Mae’s focus for the next 12 months will be on adjustments.  The data indicates that many appraisers are not using proper methodology to make their adjustments.  Murphy stated that some appraisers are still using the old standard $20-$40 per square foot adjustment on properties that are easily valued at $500-$650 per square foot.”

“Murphy explained that Fannie Mae is planning to re-evaluate appraisers based on their adjustments and the GSE will expect appraisers to comment on all adjustments if necessary. And, ‘it will be necessary,’ he said, adding that Fannie has seen a lot of under adjusting. To be safe, appraisers should document their logic and reasoning for making any specific adjustments.”

My comment: The easiest adjustment is time. Fannie got that done by requiring 1004MC. The next easiest adjustment is sq.ft. – very easy and reliable using statistics. Of course, as we all know, unless you are appraising a conforming tract home, it is very, very difficult to “prove” all your adjustments. If you know the local market makes adjustments, they should to considered in your appraisal. State regulators are looking for support for adjustments. I am seriously thinking about not using dollar adjustments for 1-4 unit appraisals. Many years ago there was a Fannie form that just required plus and minus adjustments.

I seldom make any dollar adjustments on my apartment and commercial appraisals except for time adjustments, which are easy to support. I find it very strange that residential appraisals have such a high standard. I guess it is due to the lenders telling appraisers what they have to do. I am so glad I don’t do any residential lender appraisals any more. I never like them telling me how to do my appraisals.

I don’t know how Fannie will evaluate adjustments. I make many of my adjustments on a qualitative basis as I work in an area where most homes were built prior to 1920 and are very dissimilar. I know what my market wants, and doesn’t want. If I am not sure, I ask local real estate agents. Of course, they seldom know the dollar amount.

I wonder how well “bracketing” will work for adjustment support?

click here to read the full newsletter
http://www.appraisalport.com/news_events/newsletter.aspx?id=683bbe16-bc37-4573-a436-6a680b2882e0

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Appraisers receiving warning letters from Fannie about discrepancies in Q and C ratings

I keep reading online about appraisers receiving warning letters from Fannie that they are using different Q or C ratings on the same property.

Of course we do change our opinions about a property. Sometimes we have new information or just re-think the property and change our opinion. Be sure to explain this in your appraisal.

You need to set up a way to use your comp database to check the Q and C ratings for any property you use in your appraisals. It should only take a few minutes. Hopefully software vendors will automate this for you. Bradford has software for this.

What happened to the appraisers who got the letters? Nothing that I heard of. But, Fannie may be putting them on a special list so their appraisals are scrutinized. Fannie has stated for awhile they would be sending warning letters.

Why is Fannie looking at Q and C ratings? Who knows why they picked these factors. Maybe because they are absolute. But, I suspect that other factors are being looked at or will be coming soon. I don’t think they would want to get into the very hot issue of GLA…

Remember, Q and C ratings are absolute, not relative. If you don’t agree with this, don’t do appraisals for Fannie Mae loans as that is in their Scope of Work.

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Bracketing – lenders gone wild!!

Filling up an appraisal report with “comps” that “support” adjustments is a hassle for appraisers and often does not contribute to the accuracy and reliability of the subject’s value. Note that the “comps” are sales, but not necessarily comparable sales.

Sure, it often works fine when you are appraising a typical home in a conforming tract with few adjustments. But, what if you work where I do, where most homes were built prior to 1930 and many Victorians were modified over the years? I am hearing about appraisers being asked to use sales from 2-8 years ago for “bracketing”. What if you have an “oddball” home in a conforming tract, such as a home with a large addition or an “inlaw” space?

One of my first appraisal clients was a local lender who still has an appraisal department, is very savvy and treats their fee appraisers as professionals. They specialize in Fannie Mae loans. I recently spoke with an appraiser who does appraisals for them. She said they were asking for “bracketing”, including asking their appraisers to consider using very old sales if necessary.

Why are lenders asking for “bracketing” of adjustments? The same reason we have been hearing since 2008. They don’t want Fannie to require buybacks of the loans they sold to Fannie. They are also worried that Fannie will not buy a loan. I have noticed that lenders are often like sheep. When one does it, or says it should be done, they all do it.

Perhaps they are doing this in order to have some sort of “support” for adjustments. I guess they finally figured out that putting “adjustments done using matched paired sales” in an appraisal doesn’t mean much.

More important, state regulators want to see “support” for adjustments. I don’t know how to “support” all the adjustments in many of my appraisals. I know what buyers will pay more or less for. But, the exact dollar amount can be very difficult to determine. I don’t think it is right to conclude an incorrect value just because I cannot prove the exact dollar amount. Matched paired sales and statistical analysis doesn’t work for many adjustments. Matched paired sales can be manipulated and statistical analysis often does not work due to lack of data.

Market conditions is the easiest adjustment. Square footage and number of bedrooms, lot size, can often be supported statistically. If I spent many, many hours I might be able to “support” some of the other adjustments. But, would my appraisal be more accurate? Does my scope of work agreement with my client include spending 2 weeks or much more on a home appraisal for a loan?

Appraisers should consider what affects value. I worry about appraisers not making adjustments that are indicated by the market because “support” can be very difficult resulting in a less reliable, or inaccurate, value.

I have been thinking about not using any adjustments in my non-lender residential appraisals. Instead I could just use plus or minus signs. Why? I can’t “prove” most of the adjustments for my state regulator. I worry about losing my appraisal license. My clients don’t care about dollar adjustments.

What’s the answer? The only answer I can think of is to carefully pre-screen appraisal requests so you only accept appraisals of conforming homes in conforming tracts.

Should you do bracketing when the sales you use are not comparable? Some appraisers refuse and others do it. In my business, when requested to include information that is not relevant to the value, I always put “Included at client request. Given no weight.” Only you can decide what works best for you.

I am writing an article for the August issue of the paid Appraisal Today about making more money increasing your hourly billing rate. Working in conforming tracts is Number 2 of my primary suggestions.

To subscribe, and increase your hourly billing rate, click on the ad below!!

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Fannie's Appraiser Quality Monitoring(AQM) FAQs July 2014

I did not compare these FAQs with the 2013 FAQs but they seem very similar.

The Q&As below may be new or revised:

– Will appraisers have the opportunity to appeal or offer a rebuttal?

– What should an appraiser do if he or she believes that the rebuttal would violate the Confidentiality section of the Ethics Rule as set forth in the Uniform Standards of Professional Appraisal Practice (USPAP)?

– What actions will Fannie Mae take with respect to specific appraisers?
Part of the reply: Fannie Mae will provide information directly to appraisers whose appraisal reports exhibit a pattern of minor inconsistencies, inaccuracies, or data anomalies. The intent and expectation of communicating these issues to appraisers is for training and educational purposes, and to provide them with an opportunity to improve their work. Future appraisal reports from those appraisers will be monitored to assess improvement.
https://www.fanniemae.com/content/faq/appraiser-quality-monitoring-faqs.pdf

Fannie posts a list of appraisers subject to 100% review of their appraisals or are not approved to do appraisals for Fannie Mae loans. The Appraisal Quality Management list is only accessible to lenders who sell loans to Fannie. The last list was posted in May.

My comment: Maybe a few of those appraisers hiring armies of people to do their inspections and drive comps will get caught. For example, completing 40 appraisals a week in urban areas or 10 appraisals a week in very rural areas. Of course, they can make lots of money working for very low AMC fees!!

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Low appraisal fees

Appraisal Fee vs. the Cost of Gas

Excerpt:

Two decades ago, gas cost about a dollar per gallon.  Let’s face it – almost everything (milk, eggs, etc.) was cheaper, including obtaining and maintaining your appraisal license. But surprisingly, one thing that has pretty much stayed the same is the amount you charge for an appraisal. In 1994, the average appraisal fee for a residential property was $320. Today, the average appraisal fee is $350. This is a 9% increase over 20 years, far below the rate of inflation.  In inflationary terms, this means we are currently being paid less than we were 20 years ago.

Let’s compare the average appraisal fee to the cost of gas during the last 20 years. … Gas has increased 239% over 20 years while the amount appraisers collect on average over the last 20 years has increased only 9.375%. This is a pretty scary picture for appraisers.  After factoring in the AMC percentage (25-50%) and our overall higher operating costs, it’s amazing that any of us can survive in this business.

My comment: Interesting analysis. I have been setting my residential non-lender fees based on what borrowers are paying for loan appraisals. I am still slightly under those fees. But, if prospective clients call around, some appraisers are charging much lower fees, even close to typical AMC fees. Why? The same reason many appraisers have always worked for low fees, even prior to hvcc. Fear and Greed. Afraid they will never get another assignment (Fear) and don’t want to turn down any assignments (Greed). This applies to all types of businesses, not just appraising. Remember the Primary Rule of Business – There is Always Someone Cheaper. Sometimes competing on price works out, such as Walmart. But, for most businesses it is a death sprial to the bottom.

Click here to see the graph, read the full commentary and comments, and post your own comments!!
http://www.frea.com/blog/appraisal-fee-vs-cost-gas

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Why You’re Not Charging Enough For Your Work, And How To Change That
Source: Forbes magazine. It’s not just appraisers!!!

Excerpts:

“If you’re making $50,000 or less in your business, it’s not a business, it’s a job, and it’s not a good job either.” … If you were working for someone else, and had to toil for 18 hours a day to make ends meet and still generated less than $50,000, you’d say something would have to change, right?”

4.  Develop stronger boundaries. Start saying “no” to outlandish requests for your time and effort.  Know what your time is worth, and demand respect for that.

6.  Charge 20% more starting today. Just do it.  Then figure out what the right number is within the next few months, and start charging it. You can transition your existing clients to your higher fees in a more gradual way, but new customers and clients need to pay you more, starting now.

Worth reading. Thanks to appraiser John Carlson for posting this most interesting link!!
http://www.forbes.com/sites/kathycaprino/2014/06/28/why-youre-not-charging-enough-for-your-work-and-how-to-change-that/

Help for appraisers who have been kicked off the FHA Roster

Help for appraisers who have been kicked off the FHA Roster

Awhile ago an appraiser who had been removed from the FHA Roster contacted me. Unfortunately, I didn’t have any advice at that time except to google and see if anything turned up. I told him that when I was on the old FHA panel in 1986-1988 I heard about appraisers who went to court to be put back on the panel. Since I was new to FHA then many of my appraisals were reviewed by the local FHA regional office, so I knew if I was doing them correctly. VA still has a policy of reviewing.

I don’t know if FHA regularly reviews its appraisers now. There are many, many more appraisers since the Roster was set up, open to all licensed appraisers. Only certified appraisers are eligible now.

This is much more important now, as FHA will be suspending or removing appraisers from their roster.

Fortunately, the National Appraiser Association
http://www.naappraisers.org  contacted Ted Whitmer, a Texas MAI and attorney, who defends appraisers. On June 26, he filed an Amicus Curae brief for NAA in support of reversal of appraisers who had been removed from the panel. Link to the brief posted on the NAA web site: http://www.naappraisers.org/HUD-AMICUS-NAA-6-14.pdf

Here are some excerpts from the brief:

Our organization is (National Association of Fee Appraisers) concerned that The Department of Housing and Urban Development (HUD), by its own admission, was removing appraisers from their roster from 2001 until 2012 with no “due process whatsoever. HUD only started “due process” of removing its appraisers after appellant filed a lawsuit in Federal Court in 2012

By HUD’s own admission they failed to provide any “Due Process” to appellant from January 2010 until April 2012 when he was simply deleted from HUD’s approved list of appraisers in January 2010. The District Court omitted from its opinion an explanation for the lack of any “Due Process” provided to
appellant from January 2010 until April 2012. Depriving an appraiser of his FHA license can be devastating to his livelihood.

What do you think? Post your comments below!!

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