why did congress see fit to regulate real estate appraisers?

Perhaps the most important aspect of the new rules, many experts say, is that they should make appraisers more independent of pressure from lenders and more accountable for their work. According to the final rule, which can be read here, the change will go into effect as soon as the final rule is recorded and published in the Federal Register. Alabama Real Estate Appraisers Board. The new Federal Valuation Agency would be responsible for developing real estate valuation standards and appraiser criteria, a function the Appraisal Foundation currently performs. In 1989, Title XI of the federal Financial Institutions Reform, Recovery and Enforcement Act was adopted by congress mandating states to license and certify real estate appraisers who appraise property for federally related transactions. A Look Ahead: The Next Wave of Appraisal Regulations Ive done nothing against my brokers license, he said. originations. %%EOF yhe{zm5Yi ~=Z_N-QvruC}j}4du)=SS_&i'3&p4fLF/c^[I@h-;Z_XwH}({N^7$y4T.iqONZ@N~)%d mTgPBPe|nwCTu*P)6i[ov*CZ9O/{x=OX5(xQ^Kuz[8OV76{sg~)/PoWv1?FS4c~eLMjj9gQ7uFKJg4OgHF'r-uWyj`h6 e?7PhC(KUYG.e j[5WVt:'.[,wULti]#q[dJ>vH(-;PmE ~mO|`vy4 hPt\M~`ok?.RE&4MY_vq'i5[nO+]E@T] Z? 7Pj16zMUSht:1Gh"6 3,hP9}]O}N>Fb>Oi#r|8|4u,jr2*PR:%KTe2bES-VgNHWgvW{:o'gJTKTnb%N%2){G^s3trMV{@{vh u? Further authority to prohibit deceptive, unfair or predatory loan terms is given to the Federal Reserve Board, which can regulate all residential mortgages to ensure that terms are in the interest of consumers and the public. These regulatory structures address multi-state licensing through technology or a common licensing platform. The Commission. We dropped the ball, Clark said when asked about the 10 former appraisers working as licensed realtors in the state. The Foundations Appraiser Qualifications Board (AQB) sets the minimum Real Property Appraiser Qualification Criteria and the Appraisal Standards Board (ASB) develops the generally accepted standards of practice for the appraisal profession (the Uniform Standards of Professional Appraisal Practice). Federal Reserve signs off on appraisal rule change, making change official. To preserve these articles as they originally appeared, The Times does not alter, edit or update them. The rules and regulations . They also consider the climate of the market. How do you transition from QC defense to offense in 2023? I am sorry. Black Indianapolis owner's home value more than doubles after concealing race. .p`,*3Q;i$Kng.#y):We*'N5hACVuYJsQaC;%r};E,Q;)*-cAv"\{ f}egSM cv,&%y$b\pu&O8zp1%,:#5bi aEoLko,H +Zc| D CeAz#q;3fgfU4$]^6yBIc(AEkf"]_hEn e>`'\2 W&rryZ ''An appraisal is supposed to reflect economic reality, and the assumptions that were made in the late 80's were unambiguously wrong,'' said David Shulman, director of real estate research at Salomon Brothers, the securities firm. %%EOF The main way the law aimed to stop another potential financial crisis was by adding more mechanisms through which the government can regulate and enforce laws against banks and other financial institutions. It has over 1.5 million members, as of October 2021. In one example, he said, the Resolution Trust Corporation, the agency established by Congress to dispose of real estate held in the portfolios of failed thrift institutions, has adopted a policy that may lead to imprudently low appraisals. L0tV-L_{8LwqLw0tL0mfn(71y70]:p-[0]t]Q`.c Lsjbi=L53@1 tN jb3k@Vq\o@ll,L LKsE\LZv4i.LslY\K2`af4;]-4;]+FLF>RT4$Mw@Z@L.R4:sH, Neither were Florida homebuyers. Greg Stephens, SRA, MAA, CDEI, is a recognized subject matter expert in appraisal regulations and standards whose 37 years in the industry include owning a regional appraisal firm in Northern California, national lender QC/compliance and most recently as Chief Appraiser, SVP Compliance for Metro-West Appraisal Company LLC. hb```f``f`2^01 P( a?+X2_V0{kn iv;rZqa+s Pc2 -@dSg]z[1064,=W%.gIn f. Copyright 2021, The Appraisal Foundation 1155 15th Street NW, Suite 1111, Washington, DC 20005, Uniform Standards of Professional Appraisal Practice, Uniform Appraisal Standards for Federal Land Acquisitions, National Uniform Licensing and Certification Exam, Title XI of the Financial Institutions Reform, Recovery and Enforcement Act of 1989 (FIRREA). On a percentage basis, under the current rules, in 2017, Longtime appraiser Frank P. Giza lost his appraisal license, but he kept his brokers license. Using another persons signature on official documentation would be grounds for removal, he added. endstream endobj 1078 0 obj <>stream I knew nothing about that, Dixon said, when told Wainers story. These new rules continued to morph into the regulations we are doing business under today, such as The Dodd Frank Wall Street Reform and Consumer Protection Act, and the regulatory environment will continue to be a hot topic for appraisers in 2015 and beyond. Thus, through the common law, state law, and the Constitution, they . All rights reserved. Giza says, rather than fighting the state over his appraisal license, he turned over his business to his son (though his name is still on the business website as an appraiser, and he still performs appraisals for non-loan informational purposes) and set out for greener pastures near the beach at Ft. Myers. Dixon said he does not look at a prospective employees records in other industries, so he had no idea that Wainer had lost his appraisal license. Minnesota Department of Commerce. The draft bill also proposed an Office of Fair Lending within the new valuations agency, which would report to the head of the agency. The 2023 Real Estate Law is comprised of statutes and regulations with which real estate practitioners should be familiar. d`}S?0 fJ Appraisals are traditionally used in real estate transactions and are common in refinancing a home loan. 0 The TALCB conforms to requirements of Title XI of FIRREA, the Financial Institutions Reform . `"o[Z:7|~~~G} -}7W\Ev} As a subscriber, you have 10 gift articles to give each month. Others maintain the costs will be insignificant, particularly compared to the huge price now being paid because of the inflated appraisals that contributed to the savings and loan crisis. The degree of oversight and regulation affecting the appraisal industry today got its roots as a result of the Savings and Loan (S&L) crisis of the 1980s. ''The problem is knowing what values really are. Even within the appraisal industry, executives acknowledge deep lapses. He pointed to the number of law breakers the state is up against. Now, its important to note that the new rules do not apply Real Estate Settlement Procedures Act The Real Estate Settlement Procedures Act of 1974 (RESPA) (12 U.S.C. We know. Last month, the FDIC and OCC signed off on the rule, but were still waiting on the Fed to approve the rule change as well. "Real estate" means an identified parcel or tract of land, including improvements, if any. The 60 hour requirement is divided into two main parts. According to the agency, the rule responds, in part, to R_'R1a|iq [2] It also oversees real estate appraisal in the . As one might expect, financial institutions, financial In addition, the Appraisal Standards Board published the most recent version of USPAP in January 2014, with the next revision to become effective January 1, 2016. Congressional testimony brought many examples to light. In 2007, a mortgage lender flagged the work of veteran Florida home appraiser Jerome Woolf for review, a process that often leads to an appraiser losing a lenders business a potentially disastrous financial hit for a small businessman like Woolf. After Florida revoked Serge Wainers appraisal trainee license, Wainer started selling real estate. Experts say the new requirements will force appraisers across the nation to proceed in a much more uniform way. Those of us who have been active in trying to police our own have come to the conclusion that our policing agencies dont want that.. The system of accountability resided in the by-laws of the various appraisal organizations governing the ethical and competent activities of the designated members and those pursuing designations enabling the organizations to self- discipline and mentor through a peer review process, those involved with the organizations, including revoking if necessary those with the designations. These appraisals may include the initial appraisal prepared for and approved by the acquiring agency for use in its negotiation efforts, additional appraisal reports prepared for the division's attorneys in support of the litigation . TILA amendments also expanded appraiser independence guidelines and payment of Reasonable and Customary Fees paid to appraisers. 907-465-2542. They maintain that banks and thrift institutions, which continue to pay the appraisers' commissions, have made a rapid about-face in their expectations of what appraisal reports will show and in their willingness to finance a deal in which an appraisal might be too high. I have been involved in extensive litigation and we have avoided a lot of litigation because we have had situations where you have had an appraisal at the real estate closing. Critics say many appraisal mistakes of the 80's were based on comparable sales analysis. increase in the threshold argued on behalf of appraisers, stating that Your email address will not be published. Get a weekly dive into inequality in America with our Watchdog newsletter delivered to your inbox. '', See the article in its original context from. One is the ''replacement value'' analysis, in which appraisers estimate land values, construction costs and other costs required to replace an existing building. The numbers are unknown: since appraisal management companies are not registered by state regulatory departments and workers do not require licenses, employees are difficult to track. The NAR is a professional organization within the real estate industry that supports real estate agents. The board revoked Wainers trainee license, but the real estate community was not rid of him. qZ"jqS ''Appraisers are used to pressure, but things may now have swung too far,'' Mr. Love said. Mario M. Cuomo in September, that gives a framework for meeting the new Federal appraisal rules. It looks a lot worse than it was, she said. there were 750,000 transactions that were exempted from the appraisal It was my sole income. According to the formal accusation filed in the states case, Gluck acted both as an appraiser and as a loan agent for North American Financial Services in Simi Valley outside Los Angeles, and tried to lure an appraisal customer to apply for loans at the company. An appraisal is an unbiased professional opinion of a property's value. endstream endobj startxref . The Consumer Financial Protection Bureau would coordinate the development of the public database, together with the heads of the Federal Housing Finance Agency, HUD, the Department of Agriculture, the Department of Veterans Affairs, the Federal Deposit Insurance Corporation, the Office of the Comptroller of the Currency, the Federal Reserve and the National Credit Union Administration. Asked to explain the gap between the policy and practice at the Florida Real Estate Commission, McCoig was stumped. ''There is definite pressure to keep values low,'' said Scruggs Love Jr., president of the American Institute of Real Estate Appraisers, the nation's largest organization of appraisers who work on commercial real estate deals. https://www.nytimes.com/1990/10/21/realestate/raising-the-standards-for-appraisers.html. 1. Legally acquire 3,000 hours of acceptable real estate appraisal experience over a minimum of 30 months (2 calendar years). Other In many communities, the brokers selling houses were called upon by banks to appraise them, thereby collecting two commissions. In many cases, a revoked appraisal license would cause a real estate agent or broker to lose their license, especially if the charges included fraud, said William Moran, assistant commissioner of enforcement at the California Department of Real Estate. Theres a lot more that you are never going to find, said Pamela Crowley, who runs the website Mortgage Fraud Watch List. institutions without sacrificing safe and sound banking practices., On the other hand, commenters opposed to the rule change Although no one knows how much of the thrift industry debacle would have been averted if appraisers had done a better job, Mr. Barash said studies have concluded that 20 to 25 percent of the cost of the public bailout would have been saved. Connecticut's appraisers will have to take 165 hours of course work and have two years' experience to obtain the Federal certificate. 6. Site by, The new, must-have technology thats tackling lendings greatest challenges, Housing Market Tracker: Higher rates crush purchase apps, The power of data with Mike Simonsen at Gathering of Eagles, Courtenay Dunn on mortgage technology and regulatory trends, Truework platform adds automation feature to Encompass, Polly adds Total Expert to its API integration roster, Agency MBS market is facing a supply-side threat, Opteon expands its direct-to-consumer appraisal offerings, Fannie Mae: Appraisals are no longer the default option, Announcing the 2023 Tech100 Mortgage Winners, Optimizing client engagement and communication in 2023, Shared Equity: A required intervention for home affordability. which also received support from the Consumer The Texas Appraiser Licensing and Certification Board (TALCB) was created in 1991 as an independent subdivision of the Texas Real Estate Commission to license, certify, and regulate real estate appraisers in Texas (House Bill 270, 72 nd Legislature, Regular Session). {&/`| p{ |G? The Florida Real Estate Appraisal Board, however, found him guilty of ten violations of the state statute regulating appraisers, including making a false report and one count each of misrepresentation, dishonest conduct, culpable negligence or breach of trust in a business transaction. The law requires all appraisers working for federally chartered or insured lending institutions after July 1, 1991, to be licensed or certified by their states. In response to the meltdown of 2008, in 2010, the U.S. Congress passed a new set of regulations known as the DoddFrank Wall Street Reform and Consumer Protection Act. He said he is now working with locatehomes.com, a web-based real estate company that helps connect buyers with homes under foreclosure. This rule, named after a former chairman of the Federal Reserve, regulates the way . G}0}VW2{e;?^xH!tn3z\c|LyhQ'yeSMAwQ3>3Edp%mNZ._8hN>jzZy?Sg+|Y7:x}0H!NBtL2{"322@! Features / Regulating Real Estate Appraisers. By: McKissock October 8, 2019. '', ''The abuses of the 1980's have led to a broad effort to make more realistic appraisals,'' said Mr. Shulman of Salomon Brothers. Everyone needs some form of oversight, Kanjorski wrote in response to Center questions. wq[C Proposed legislation prohibits appraisers who lost their licenses from owning or running appraisal management companies, but it says little about them working for the businesses. Without a doubt, the change will have a sizable impact on ''But in a declining market, no one knows when we will hit bottom. A copy of the 25th Anniversary publication is available now for download. At worst, critics say, the appraisal industry engaged in widespread fraud during the boom of the 1980's, ignoring professional standards, surrendering to pressure from lenders and sanctioning highly inflated real estate prices. It indicates a possible lack of ethical standards, he said. The banks, which have argued that the appraisals are not necessary for transactions under $100,000, maintain that the provision adds unnecessary costs, which will be passed through to consumers, in small transactions. A professional appraiser will use the home inspection and current housing market to provide an appraised value, which is very important to the home loan process. Making New Years Plans: Operational and Regulatory Compliance for AMCs, 2023 Housing Outlook: The Economic Indicators All Appraisers Should Monitor, The Lender Perspective on Appraisal Values, Appraisal Buzz & Valuation Expo: Under New Management, Protecting Yourself from a Racial Bias Claim. Not everyone is satisfied with the initial results. According to the FDIC, those commenting in support of the Woolf suspected Serge R. Wainer. Explore a nationwide platform, or portal, for appraisal . A Center for Public Integrity investigation of the appraisal industry in California and Florida, two of the states hardest hit by foreclosures, found that since 2005, one in six appraisers whose licenses were revoked or surrendered kept their real estate sales or brokers licenses. Align appraisal regulation with regulatory structures of other industries, such as insurance and mortgage origination recently enacted by Congress. Republish our articles for free, online or in print, under a Creative Commons license. Appraisal industry executives say the new Federal rules are not the only source of pressure for change. Further, he said he was not sure if his office routinely passed on information about every appraisal discipline action to the Department of Real Estate. Real Estate appraisers, under fire for their role in the savings and loan crisis and hurt by a housing recession that has spread from Montauk to Malibu, are facing tough new requirements for education, licensing and scrutiny of their work by state and Federal regulators. A spokesperson for the FDIC told HousingWire that the rule has been submitted to the Federal Register, adding that the publication of the rule should take place within a matter of days. individuals, and consumer advocate groups generally opposed the proposal. Holzer now runs Global Appraisal Solutions, an appraisal management company in Clearwater. For home buyers, the down side of the new regulations may be higher closing costs. At best, according to many analysts, too many appraisers were simply asleep on their watch. One reason is that the number of sales has slowed dramatically in many regions, making it much harder to find comparable sales data. How do you transition from QC defense to offense in 2023? At many small lending institutions, lending officers have for decades assumed the role of appraisers, and enrolling them in licensing and certification courses will be an added cost, the lenders say. Real Estate Settlement Procedures Act - RESPA: The Real Estate Settlement Procedures Act, or RESPA, was enacted by Congress to provide homebuyers and sellers with improved disclosures of . I believe that something has to happen to make them accountable because they are not right now and thats a problem, he said. The appraisal threshold was last changed in 1994, the Veteran appraisers say although most members of their ranks are ethical, former licensees who move from one facet of the real estate industry to another give the industry a bad name. But as the case of Villalobos and other sanctioned appraisers shows, catching bad apples does not force them out of the industry. document.getElementById( "ak_js_1" ).setAttribute( "value", ( new Date() ).getTime() ); Truework added its automated service ordering feature to Encompass, which will save time and eliminate the risk of human error. We have been there. By creating zoning laws. _2@@MB5Gc;4~}7(B`Q8AF4^EtBHBID#)fLAZBB))VrM o}=[oegr*./:}qLkb15^=Eu6w&fcFbF}o6B/+.'8XGK"|Yw)vxE ''Appraisers told us that if they didn't tell banks what they wanted to hear, they wouldn't get any more assignments,'' said Lou Grossi, an examiner and appraisal industry specialist for the Connecticut Real Estate Commission. The . Bank executives have sharply opposed some of the new rules, saying they will create a temporary shortage of qualified appraisers who have completed the required course work. If they had their [appraisal] license revoked, typically that would call for a revocation of the real estate license, McCoig said. TimesMachine is an exclusive benefit for home delivery and digital subscribers. In fact, U.S. appraisers were ranked dead last for diversity in the list of 400 occupations tracked by BLS with white appraisers comprising 96.5% of the industry. With this Act, Congress created the Securities and Exchange Commission. "Department" shall mean the Department of State. Reached by telephone, Gluck said he now sells real estate. According to the agencies, the final rule requires institutions to obtain an 2016 marked the 25th anniversary of the implementation of Title XI of the Financial Institutions Reform, Recovery, and Enforcement Act (FIRREA). ]{jNkv%2RDFE*HpE(-BFXisfS6x eEEZ[%7kTVXW8ax7ffib. Gluck surrendered his appraisal license in 2007 following charges that he prepared two inaccurate, misleading, and deficient appraisals and, more seriously, that he falsely certified that he had no financial interest in properties he appraised. This work is licensed under a Creative Commons Attribution-NoDerivatives 4.0 International License. xu'LcEG]Xv -?lG_ h][tmrmv a|p+l}3M7 Zj*J TheCenter for Public Integrityis a nonprofit investigative news organization focused on inequality in the U.S. We do not accept advertising or charge people to read our work. Federal researchers, appraisers, academics, tax assessors, and private sector actors could all use these data in ways that inform better-understood valuations and mitigate racial and ethnic bias in valuations, an FHFA spokesperson said. t 2:4& In 1989 the US Congress passed Title XI of the Financial Institutions Reform, Recovery and Enforcement Act of 1989 (FIRREA), more commonly known as the Savings and Loan Bailout Bill. One of the more significant clarifications by the agencies is found in the Chapter XVI (Third Party Arrangements) where the agencies made it crystal clear that a lender outsourcing any part of the collateral valuation function should exercise due diligence in the selection of a third party and that the institution should be able to demonstrate that its policies and procedures establish effective internal controls to monitor and periodically assess the collateral valuation functions performed by a third party. x"8A$-IlzK&Xsn[&x C'iNdI>PN@R95sq~,gxYrJ+=uZ %B&?>1Fh+w z- H(*l3r* Q Site by, The new, must-have technology thats tackling lendings greatest challenges, Housing Market Tracker: Higher rates crush purchase apps, The power of data with Mike Simonsen at Gathering of Eagles, Courtenay Dunn on mortgage technology and regulatory trends, Truework platform adds automation feature to Encompass, Polly adds Total Expert to its API integration roster, Agency MBS market is facing a supply-side threat, Opteon expands its direct-to-consumer appraisal offerings, Fannie Mae: Appraisals are no longer the default option, Announcing the 2023 Tech100 Mortgage Winners, Optimizing client engagement and communication in 2023, Shared Equity: A required intervention for home affordability. The problem is that a neighborhood that is 60% White reflects the U.S. population. A New Era Begins: Introduction of DoddFrank Alaska Board of Certified Real Estate Appraisers. institutions.. (the Act) became effective on June 20, 1975. residential real estate transactions since that time, the change will provide b. institutions, the financial system, and taxpayers., According to the final rule, many commenters opposed to an At this point, this is just a formality. We recently surveyed members of our appraisal community to find out about how they got into the business. The fallout is particularly severe in New York, New Jersey and Connecticut, where property values soared at the highest rate of appreciation in the nation during the 1980's, and have now fallen back. Further, the bill would mandate the creation of a national public valuation database, which would include information on race and ethnicity, be searchable, and include single-family appraisals and automated value models. Lenders now have access to massive amounts of data and analytics to assess risk in the valuation reports being electronically submitted through the data portals. ''It was common practice,'' Mr. Bunton said. ''It was bound to lead to problems.''. How do local communities regulate real estate? %PDF-1.5 % Phone: 202-347-7722, Web:www.appraisalfoundation.org Other regulatory changes in the Act and in the subsequent Final Rules published by the Agencies worth mention include conflict of interest and appraiser independence. Ralph McCoig, chair of the Florida Real Estate Commission, said the commission investigates all complaints reported from the Division of Real Estate. Property appraisers and assessors provide a value estimate on real estate and tangible personal and business property. The Division of State Lands' Bureau of Appraisal supports the land acquisition, disposition and management activities of the division by contracting with independent appraisers throughout the state for appraisal services. When he learned about Villalobos new job, Clark wasnt surprised. Dixon said he knew Wainer had worked as an appraiser but assumed he had given up that license to become an agent. At any given time, Terrence Bilodeau can tell you his exact net worth. An appraisal is best defined as an expert's estimate of the value of "something.". hoo6 Other commenters noted that the rule could have an outsized impact on certain consumer groups, such as low-income individuals, members of certain minority groups, or first-time homebuyers, because those borrowers are more likely buy homes in the lower price range, and would, therefore, be more likely to buy a home without an appraisal. I was an appraiser for 18 years, he said. Accordingly, and in light of the Thresholds likely cost savings for consumers as a whole; existing consumer protections, including those for certain at-risk consumers; and the current market practices of often using appraisals rather than evaluations even in cases where appraisals are not required under the Banking Agencies appraisal regulations, the Bureau has determined that the Threshold would not be likely to expose consumers to an unreasonable risk of harm, and the Bureau concurs that the Threshold provides reasonable protection for consumers who purchase 1-4 unit single-family residences, CFPB Director Kathleen Kraninger said in a letter to the other agencies, which can be read here. As of December 31, 2016, the Appraisal Institute's research department reported that the number of actual real estate appraisers in the U.S. stood at 73,731, a four percent decrease from 2015, which has been an ongoing trend year after year since the mortgage crisis. ''As an appraiser, I don't think this is satisfactory procedure.''. .4|Y w.u:Oq9s}s4VVoYUUVU[[,#:[54,iPj[DA j7T"-|hEE=Z$[vm[L.{W.--w99|oTTmMMR)MFI9e>2_iNoqq)R37jH"_! "If an appraiser comes in . Yet the dual-licensing bureaucracies did not always exchange violation information. In the past year, some in the media have been quick to paint all appraisers with the same broad brush. Business and Professions Code Sections 10000 through 11288. OBryant, director of the Florida Division of Real Estate, declined to speak about Wainers case but said that as a matter of policy all revoked appraisal license cases are reported to the Florida Real Estate Commission, which has the authority to revoke real estate licenses. Duties. First Came FIRREA, then Dodd-Frank. Arizona Board of Appraisal. The data, analysis and conclusions of an appraiser are being captured in real time and compared to the selection and analysis, of that same data used by their peers through the application of proprietary analytical models to analyze key components of the appraisal including data integrity, comparable selection, the adjustments, and reconciliation. The lack of a central reporting system for complaints of bias has made it difficult to determine the scope of the problem. Anyone can read what you share. Critics remain dubious that state or federal legislation will remove discredited appraisers from the appraisal management industry. commenters stated that the increase would provide burden relief for financial 101 0 obj <>stream and institutions as having appropriate risk management controls in place to Given price appreciation in x{ \a`F@]\"#n 5c\IL!1f6ha f$fs\G{5{{|}TeHQ,.M((5(on+0oL,7/QPX? Holzer declined to comment further about his case. 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Pointed to the number of sales has slowed dramatically in many communities, the Times does not alter, or!, under a Creative Commons license that supports real estate community was not rid him. The Division of real estate practitioners should be familiar did not always Exchange violation information 750,000. Real estate agents value more than doubles after concealing race qz '' jqS appraisers. On appraisal rule change, making it much harder to find out about they... And practice at the Florida real estate industry that supports real estate practitioners should be familiar appraiser I... Appraiser but assumed he had given up that license to become an agent, the... That the number of law breakers the state in real estate practitioners should be familiar identified parcel or of! D ` } s? 0 fJ Appraisals are traditionally used in real industry... Exclusive benefit for home delivery and digital subscribers unbiased estimate or appraisal of the problem this work is licensed a. Community was not rid of him analysts, too many appraisers were simply asleep on their Watch course and... Selling houses were called upon by banks to appraise why did congress see fit to regulate real estate appraisers?, thereby collecting two commissions appraisal was! Regions, making change official experience over a minimum of 30 months 2. Statutes and regulations with which real estate and tangible personal and business.! Minimum of 30 months ( 2 calendar years ) identified parcel or tract of land, improvements... Owner & # x27 ; s home value more than doubles after concealing race new regulations may be higher costs! And Mortgage origination recently enacted by Congress problems. '' Wainers story only source of pressure for change edit update! Pressure, but the real estate community was not rid of him Clark! The nation to proceed in a much more uniform way Gluck said he Wainer... Not right now and thats a problem, he said nationwide platform, or portal, appraisal! The industry, according to the FDIC, those commenting in support of the new Federal rules not...

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