CAREA General Meeting Minutes
March 16, 2011
Moment of silence observed in honor of our former president Ross who passed away in February. Steve Ball also passed away in the past few weeks.
Introduction of new members, Registered Appraisers looking for mentors as well as anyone with a birthday, anniversary or anything special to share.
E&O class is headed to the Springs. It will be a four hour class with CE. Not to replace the CAREA meeting.
Social Networking is alive in CAREA. Please look for us on Facebook.com and LinkedIn.com
Larry Schneller with the El Paso County Assessor. He will be developing a regression analysis program for CAREA members. The program cannot be used without Excel. There will be an Excel class offered prior to the release of the program.
Marcia Waters from DORA
Division update. Fees have been reduced. $150 per year for renewal. This year they did a USPAP audit. Again the number of renewing appraisers is down by 25%. 3215 appraisers in the state. CE audit is under way now. Computer system upgrade to allow those subject to fines to pay on line. Can now pay fines with a credit card. Real Estate Manual released in January. Trying to publish a newsletter four times per year. Appraisers please make sure that your information is current with DORA.
Appraiser dismissals are held in DORA for six months. How long will the disciplinary icon remain on the appraisers profile on the DORA website? DORA does understand that the icon has become a “kiss of death” for appraisers.
Effective 1-11 all departments in DORA have been required to reduce their paper usage by 25%. They are doing all they can to communicate electronically.
DORA will not be compiling any kind of data that appraisers might use to standardize their appraisals.
Dodd-Frank Act- DORA will see many changes in their world as this act rolls out. Dodd Frank will allow for sanctions to DORA. The Dodd-Frank act will include AMC’s. The Appraisal Standards Committee looks at licensed and certified appraisers and now they will look at registered appraisers as well as supervisors. ASC will be looking at how the appraisers are being licensed. They will look at how long the investigations are taking. Are they reporting complaints in a timely fashion?
There will be a national appraisal complaint line. It will be offered at a Federal level and then siphoned down to the proper agency.
Appraisal Qualifications Board is changing licensing requirements. Licensed appraisers will need a Bachelor’s degree. Fingerprinting will be required. Another proposed change is financial fitness. Appraisers are generally the lowest paid. This impacts their financial fitness. Also proposed is an evaluation of physical fitness.
USPAP checklist now used to inform the appraiser of the deficiencies in their report. This is easier to read and less demoralizing for the appraisers.
Anyone can file a complaint. Cannot be limited to intended users. Most complaints require investigation. There are five investigators. Investigators all have appraisal experience.
Letter is issued with a copy of the complaint. Letter asks for a response and a copy of your work file. The investigator will begin interviewing. They interview experts, involved parties, etc. They gather documents, research comparables and prepare a report.
The board has a goal to educate and rehabilitate.
Letter of admonition is a letter of reprimand. Says they violated the license law but will not be pursued. It gives the respondent option to go before the board. No Icon will appear to indicate any investigation has taken place.
Stipulation of diversion. Usually requires education, fines, reviews, supervision. No icon will appear on DORA’s website.
More serious deficiencies with suspension, revocation: Stipulation for Final Agency Order results in an icon. The appraiser may either sign it and accept the decision, counter and ask that the punishment be reduced or go before the board. The Board has the final decision. Any unpaid fines are sent to collections.
Q&A
Cost Approach. You need to be able to support how you came up with the cost approach numbers. Don’t have to be in your work file but you need to be able to provide them if requested. Vacant land sites can be used to determine the land value. You have to be able to support specifically how you have come to the numbers.
Who is informed of pending or current investigations? The board cannot disclose to E&O or any other entity the existence of any active complaints. Only the involved parties would be aware.
Who is training the investigators? USPAP instructors are on staff to educate the investigators. The investigators come from the industry. They have working knowledge and experience.
Is there a list of approved mentors or supervisory appraisers that have been approved by the state and are known to be teaching appropriately? No. There are no state approved supervisors. There will be supervisor education and supervisor designation within Dodd-Frank.
Is there a statute of limitations on a complaint? There is, 1991. Complaints for work done prior to 1991 will not be investigated.
What if an AMC is demanding the cost approach be evaluated even in a market where it is not considered reliable? Meet the needs of the client, evaluate the cost approach but explain that the demand has been made but the results have been deemed to be unreliable for specific reasons.
There is a misconception that by filling out a Fannie Mae form you have been USPAP compliant. This is not true. Just filling in the blanks does not adequately report assignment results and the appraiser may need to supplement the report.
There seems to be a lack of understanding about what the summary of your analysis is. Just stating what adjustments have been made is not summarizing. There has to be some analysis done. 95% of the appraisals seen by DORA do not include adequate summarization of the analysis done.