The Appraisal Subcomette
Recently, I was made aware of a letter distributed by the Appraisal Foundation (TAF) in response to a publication by the National Association of Home Builders. The significance of the TAF letter was that appraiser have the freedom to choose whatever comps they feel are relevant to their valuation-including no arm’s length sales to opine Market Value. This practice is an apparent violation of acceptable appraisal practices. I requested and then demanded that they send me a citation supporting this argument along with one indicating that their response was sanctioned by their bylaws. They, again, refused. I then demanded the information, along with comprehensive resume’s indicating that they were competent to derive such conclusions, under the Freedom of Information Act (FIA.) They again refused, stating that they were not subject to the FIA because they are a Private Non-profit organization.
This leads me to believe that they are incompetent for their positions, and that their actions have contributed to an unnecessary geometric decline in real property values. My complaints are:
1. It is not within their purview to make requested or unrequested public comments re Appraisal Practices.
2. They are incompetent to make such statements.
3. They have no standing when it comes to an exemption of the FIA.
Curtis D. Harris, BS, CGREA, REB
Bachelor of Science in Real Estate, CSULA
State Certified General Appraiser
Real Estate Broker
ASTM E-2018 Commercial Real Estate Inspector
HUD 203k Consultant
HUD/FHA Real Estate Appraiser/Reviewer
FannieMae REO Consultant
CTAC LEED Certification
The Harris Company, Forensic Appraisers and Real Estate Consultants
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1910 East Mariposa Avenue, Suite 115
El Segundo, CA. 90245
Commercial Appraiser Blog: http://harriscompanyrec.com/blog/
We Make a Simple Pledge to
Communicate, in a timely fashion, each appraisal, analysis, and opinion without bias or partiality
Abstain from behavior that is deleterious to our clients, the appraisal profession, and the public
Hold paramount the confidential nature of the appraiser/consultant – client relationship
Comply with the requirements of the Uniform Standards of Professional Appraisal Practice and the
Code of Professional Ethics of the National Society of Real Estate Appraisers
IT’S THE LAW- Statement 7: Prohibition Against Discrimination
State agencies should be aware that Title XI and the Agencies’ regulations prohibit federally regulated financial institutions from excluding appraisers from consideration for an assignment by virtue of their membership, or lack of membership, in any appraisal organization. Federally regulated financial institutions should review the qualifications of appraisers to ensure that they are qualified for the assignment for which they are being considered. It is unacceptable to assume that an appraiser is qualified solely due to membership in, or designation from, an appraisal organization, or the lack thereof. The Agencies have determined that financial institutions’ appraisal policies should not favor appraisers from one or more organizations or exclude individuals based on their lack of such membership. If a State agency learns that a certified or licensed appraiser allegedly has been a victim of such discrimination, the State agency should inform the Agency which has regulatory authority over the involved financial institution. INCLUDING THE APPRAISAL INSTITUTE-MAI
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