Appraiser Talkback Blog

Editor’s Note: According to OREP/WRE’s HVCC Appraiser Talkback Survey, there is high interest in appraisal security. Ninety-two percent (92%) of survey takers answered “Yes” to the following question: Is being able to be certain that your clients are receiving an unaltered version or “true copy” of the appraisal reports you send them an important issue to you? This story offers one solution.

Appraisal Security Solution
by Steven Nation

Before the Internet and email, the appraisal business was largely a relationship-centered business conducted between appraisers and lenders or their agents. The relationship was primarily local and often conducted over a handshake. There was often a high level of confidence in knowing who you were doing business with. This is far from the case today.

Identity theft, altered appraisals and other fraud are rampant today as a result. Appraisers have become nothing more than a name and a number or username and password to national companies, and vice-versa; lost are personal interactions and the security of knowing who you’re dealing with. Needless to say, recent events and market forces on a national level have created an unprecedented urgency to restore confidence in the security of the appraisal transaction.

Getting snared by an identity thief who has stolen your name and/or changed the contents of your appraisal report without your permission can be very costly to your reputation and your bottom line. Nation Technologies has released the BIOWRAP System that utilizes advanced fingerprint authentication technology to bring security back to business-to-business transactions.

Preserving “True Copy” Appraisals
The BIOWRAP System provides a tool for appraisers to accurately associate their identity and credentials to an unalterable “true copy” appraisal report using fingerprint technology. Appraisers are able to track anyone who views their “true copy” appraisal reports. According to David Doering with Missouri Property Appraisal, Inc., in Jefferson City, Missouri: “The days are long gone when we could be certain that the printed appraisal report, hand-delivered or mailed, would reach its intended user intact. As appraisers, we are asked routinely to transmit appraisal reports via the Internet to often unknown users, hundreds or thousands of miles away. And while our appraisal software allows us to use an electronic signature that is protected by a password, it is naive to think that it is not possible for an appraisal sent as a PDF or in .xml format to be hijacked with readily available software and changes made at will.”

“With BIOWRAP we are able to send both narrative and form appraisal reports and other files with the confidence that the report will be received by the intended user precisely as it was sent, unaltered and complete. With BIOWRAP we know that we have a verifiable record that what we send is what the client will ultimately see. Further, BIOWRAP provides us with accountability as to the chain of custody of who opened the file and if the file has been altered,” Doering said.

The system provides guaranteed assurance of the authentication, security and accountability of appraisal reports without impeding existing technology. Clients can limit their liability and have certainty that the appraisals they receive are secure and authenticated and were created by an accurately-identified and properly credentialed appraiser. The integrity of an appraiser’s identity and credentials serve as the basis for his or her livelihood. This new technology offers that protection.

OREP and WRE Discounts
Through an affinity relationship, those who purchase their E&O insurance from OREP save $70 at sign up. Working RE readers also qualify for a discount ($35). To learn more and to obtain the discount code(s), please visit OREP.org (click Benefits) or WorkingRE.com (under left column: Appraisals and Identity Security Solution). You will find links for more product information as well.

For additional information please read Altered Appraisal Reports (WorkingRE.com, Current Issue).

HVCC Update - NAMB’s Call to Action
The National Association of Mortgage Brokers (NAMB) believes the time has come for every appraiser’s individual voice to be heard. In order for this “Call to Action” to be effective, NAMB is asking for everyone to fully participate, encourage others to join the action and continue calling and emailing every day, until advised to stop by NAMB. To read NAMB’s press release to learn more about who to contact and what to say, please visit WorkingRE.com, Premium Content: NAMB’s HVCC Call to Action.

By David Brauner, Editor Working RE

Editor’s Note: According to our survey, HVCC does not appear to be the panacea for appraiser independence many had hoped. Rather, many appraisers say it is the final straw that will break their backs because it bans them from doing business with their clients. You’ll find survey results to date including how pressure on turn times and fees effect appraisal quality, and much more in the upcoming print edition of Working RE.

AMC Pressure
The Home Valuation Code of Conduct (HVCC) is intended to support appraiser independence and thwart coercion and inflated values by removing mortgage brokers from the appraisal ordering process. As a result, we now see orders flowing from Appraisal Management Companies (AMCs). FHA loans are not effected by HVCC.

You may recall that HVCC is part of a private agreement between New York Attorney, General Andrew Coumo, and Fannie Mae and Freddie Mac. (In an ironic postscript, U.S. officials seized Fannie and Freddie last fall and put them into Federal Conservatorship.) Another irony is Cuomo’s investigation began with scrutiny of a vendor management company- eAppraiseIT. The complaint issued by Cuomo accused the company of inflating the values of home loans under pressure from Washington Mutual Inc. Both companies deny the accusations (Premium Content: eAppraiseIT, WAMU Blow Up, Fannie, Freddie). The investigation by Cuomo included subpoenas of Fannie Mae and Freddie Mac for details about WAMU’s loans and their due diligence practices related to the appraisals. As a result of the agreement which includes HVCC, Cuomo terminated the inquiry into Fannie and Freddie.

So, what is the effect of the agreement so far on appraiser independence, now that orders flow through AMCs? Here is how appraisers responding to the OREP/Working RE HVCC Appraiser Talkback Survey answer the following question: “With the AMCs you work with, are you asked to re-examine reports with the intention of trying to ‘make the deal work’?”
- Always: 3%
- Often 12%
- Sometimes: 39%
- Never: 46%

Fifty-four percent (54%) then, say they experience this type of pressure from AMCs at least some of the time. What do you say? Your responses matter, whatever they may be: complete the survey today and be heard. Find links to the survey and blog at left.

HVCC Fallout
Many appraisers report how badly HVCC is hurting their livelihoods many say it’s catastrophic. To see what regulators think, you will find posted at WorkingRE.com a response from the Federal Housing Financing Agency (FHFA) to an inquiry made on behalf of an appraiser by Peter J. Visclosky (D - IN) from the U.S. House of Representatives (Sidebar: FHFA Letter Regarding HVCC). The response letter from FHFA states in part: “The Code (HVCC) does not alter the fundamental business models that exist in the appraisal industry, nor does it alter the fees or charges of any participants in the valuation system.” 

The following comments, from the OREP/Working RE Appraiser Talkback Blog, are representative of many.

“I have had it with government intervention in the name of helping appraisers not succumb to pressure from mortgage lenders. I have run my own business for seven years. I picked and chose who I worked with in order to keep my license clean, so I could trust who I was working with and they, in turn, could trust me to keep them out of trouble. Since HVCC, I have lost every one of my clients! What happened to free enterprise? I believe HVCC is unconstitutional! I am being helped right out of the business. What other business in the U.S. is told they can no longer work with, talk to, or have a relationship with their current clients? I don’t need a mediator to run my business, especially one that seemingly has no rules of engagement.”

And this comment:
“I don’t think there is any other job where you can’t put your name out there, do a great job and expect your good product and service to be good advertising for you. In fact, there is no point to advertise at all. We have no freedom to run our business. We are at the mercy of being picked out of a hat. I think the issue here is bigger and worse than we can imagine. We have lost all control and have no freedom to be INDEPENDENT FEE APPRAISERS, as the name suggests. All the work and effort….It is extremely hard to get an appraiser’s license in this state (CT) with all the classes, finding a supervisory appraiser and actually getting enough assignments for your hours needed (not to mention your split will be ridiculously small now), and now you have to have a college degree and the state exam is very difficult with a very low pass rate. Who is going to be stupid enough to enter this field now?”

The summer issue of Working RE (mailing in early August) will have much more survey results. Judging by the blog and comments left by survey takers, the following survey results is more fallout from HVCC:

While 74 percent (74%) of survey takers answer that “yes” they are “generally satisfied with appraising,” just over half (51%) say they don’t expect to be appraising full time five years from now.

Petition to Reconsider HVCC
Find a link at WorkingRE.com to a petition to reconsider HVCC (Sidebar: HVCC Petition). So far, over 23,000 persons have signed.

From our survey; Question: “Are you in favor of the HVCC as written?”
Answer: 93 percent (93%) say “No.”

Diversifying with BPOs?
Appraisers have long bristled at the unfairness of BPOs but perhaps this issue needs a fresh look.

As most appraisers know, BPOs are a kind of “loophole” of sorts- a lower cost and less rigorous valuation product that competes with appraisals but whose “practitioners” are not required to be licensed nor follow USPAP guidelines. BPOs have eaten into appraisal business for years because they are faster and cheaper.

Recent legislation that passed the U. S. House of Representatives last month, the Mortgage Reform and Anti-Predatory Lending Act of 2009 (H.R. 1728), contains provisions restricting BPOs as well as addressing AMC licensing and other related issues (more in the upcoming print issue of Working RE).

The understanding of most appraisers is that they are forbidden from doing BPOs because they are licensed; under licensing any “opinion of value” must meet USPAP requirements. A recent story from the Appraisal Institute puts forth the opinion that appraisers can do BPOs, as long as they are also licensed real estate agents/brokers.

The story, authored by Stephanie Coleman, MAI, SRA, Senior Manager of Ethics and Standards Counseling at the Appraisal Institute, focuses on circumstances where a lender is not required by regulation to obtain an appraisal or an evaluation. This is timely because of the huge inventory of foreclosed property. When a home is foreclosed upon and becomes real estate owned, lenders need to establish a value in order to dispose of it.

The story says that an appraiser who is also a real estate agent may provide a BPO in these cases and that when doing so, they are not bound by USPAP. The story quotes Advisory Opinion 21 USPAP Compliance, which says that USPAP applies only when one is acting as an appraiser. Appraisers providing this service as an agent/broker must make it clear that they are an appraiser, however, even though they are not acting as an appraiser when providing the service. The story opines that it would be a “misrepresentation” for an appraiser to do a broker price opinion if they were not also a real estate agent/broker.

Working RE recommends that you contact your own state licensing Board before proceeding. You can find the story, “Matter of Opinion: How and When Appraisers Can Expand into BPO Work,” at the Appraisal Institute website (Valuation Magazine, First Quarter 2009).

Free Fannie HVCC
Please visit WorkingRE.com for the link to Fannie Mae’s newest guidance on the HVCC - a recorded web seminar you can access for free (Sidebar, Fannie Mae’s Guidance on HVCC).

Editor’s Note: Francois (Frank) K. Gregoire IFA RAA, long active in Florida politics, is in favor of AMC regulation in his state. Here’s why.

Call for AMC Regulation
by Francois (Frank) K. Gregoire IFA RAA

The Florida Legislature passed a record low number of bills this past session. Like many states, their time was consumed with trying to balance a budget in tough economic times. The bill to regulate appraisal management companies (AMCs) was not considered. However, the team of appraisers, professional associations and the Florida Real Estate Appraisal Board is lining up support and legislators for the 2010 Legislative session.

Unlike some of my appraisal brethren, I believe AMCs provide a service and are legitimate businesses. AMCs existed long before the federally-mandated licensing, certification and regulation of real estate appraisers. Quite a few lenders opted to utilize the services of AMCs and a couple of AMCs offered quite a bit of assistance to get appraisers and appraisal firms up to speed with appraisal software and office management.

My own firm, Gregoire & Gregoire, Inc., received complimentary appraisal forms software from one of the early AMCs. Although my firm was already using computers for appraisal reporting and some analysis, the software enabled us to move from a mini-computer to personal computers and enabled us to update to revised forms more quickly. Gregoire & Gregoire, Inc. enjoyed a mutually beneficial relationship with that AMC for over a decade.

Souring Relationship
Unfortunately, that relationship started to sour with fee pressure, turnaround pressure and what appeared to be the AMC’s accounts payable department taking advantage of the “float” in their payment procedures, policies and responsiveness. We arrived at the realization that it cost the firm just one dollar ($1) less to send an appraisal report out the door than the fee received from the AMC. The seven appraisers, including the principals, were extremely busy but there was no profit. Instead, we had a flurry of activity and paper and constant phone calls for status and appointments. Our requests for modest fee adjustments were refused. Gregoire & Gregoire, Inc. decided to reduce our volume, enhance our quality and concentrate on the segment of the market more interested in quality than cost and speed.

Recently, a national AMC made a request for my expert services. Apparently, the company had an assignment in my market area that required appraisal review services and testimony from an expert witness. Although the company has dozens of appraisers on their panel active in my service area (Pinellas County, Fla.) they sought me out first. In telephone conversations, I was assured that I would set my fees, determine the time required for each phase of the assignment and would not have to endure constant requests for status and updates. All they asked was for me to review the engagement contract, sign and return it to them.

When the “package” arrived, it was the standard AMC agreement, compelling me to agree to 48 hour turn time, status updates, a fee schedule and other assorted items contrary to their verbal assurances. When their attention was directed to the conflict between their written terms and their verbal assertions, I was instructed to modify the agreement to my liking and return it. Although the assignment had the potential to be worth my time, I decided to let it pass. If the AMC’s right hand does not know what the left hand is doing up front, the potential for conflict in the future outweighed any perceived benefit to me and my firm.

The Florida Real Estate Appraisal Board was interested in the regulation of AMCs long before there was a Home Valuation Code of Conduct. After reviewing hundreds of workfiles and reading the written and email requests from AMCs to appraisers, the problems were clear. Many, not all, AMCs were making representations to their clients that could not be met and appraisers were pressured to make miracles happen; often to the detriment of the public and appraisers’ professional license and certification.

Fairness and equity was and is needed. What is proposed for Florida is a fairly simple act that will require registration of AMCs along with their officers and directors. It is only fair that AMCs meet the same character qualifications as appraisers. We also propose that AMCs and their officers and directors comply with the same laws, rules and regulations applicable to Florida appraisers, including the Uniform Standards of Professional Appraisal Practice, nothing more, nothing less.

About the Author
Frank Gregoire, IFA RAA is a State-Certified Residential Appraiser, #142, active in a wide variety of valuation, consultation and expert witness assignments in Pinellas County, Florida. He operates the blog: Appraiseractive.blogspot.com.

By John Lifflander, ASA

Editor’s Note: In this installment of Valuation Issues and Answers, John Lifflander, ASA discusses liability landmines and how to avoid them in this new world of bailouts, tax credits and - business as usual.

The current economic crisis was largely precipitated by loose credit and loose lending standards. Part of the loose standards involved property owners buying properties with no money down. Last year, it was reported that over 40 percent of recent buyers had purchased their homes without paying one cent. In fact, with concessions given to buyers, many actually received money out of escrow, so they were effectively paid to buy a house!

The Federal Reserve kept interest rates at historic lows, which effectively increased prices. The reason is that when shopping for a house, most people look at the monthly payment and not the total price. Consequently, values typically increase when rates decrease. There are, of course, a myriad of other reasons for our current debacle but these are some of them.

Understanding this, one might think a solution would be to stop the bad practices that caused the problems. However, that is not what is happening. Instead, interest rates are now lower than they have been in over 50 years, with the Fed Prime Rate at zero percent. Moreover, an incentive has been offered by the government and an $8,000 tax credit for new homebuyers. The Veterans Administration and the United States Department of Agriculture are still offering no-money-down loans and the Federal Housing Authority is still offering loans with down payment of about three and a half percent.

Moreover, real estate agents are writing up offers with concessions, which effectively means that buyers are still purchasing with no money down and often getting money back. This essentially means that some buyers are still being paid to buy homes. Obviously the government hopes to get us out of this crisis with the same bad behavior that got us into it.

$8,000 Tax Credit
What are the ramifications of the current market for appraisers? The $8,000 tax credit is artificially increasing the values of some properties. Our firm is finding that buyers who are getting this credit are often paying more than typical market values. This is why an appraiser may not find comparables that support some sales: this is an artificial bounce to values but it is not a value increase which is inherent in the property. In other words, it cannot be passed on to another buyer and if the property is foreclosed upon, the value of the tax credit will not be realized. For this reason, appraisers should be very careful with new sales which do not line up with the purchase price.

Value of Concessions
Added to this artificial increase in values are two other issues. First, because of the Prime Rate decrease and the money being pumped into banks, courtesy of U.S. taxpayers, interest rates are even lower than they were in 2002 and 2003 when the market was increasing dramatically. Some fixed rates are four point eight-five percent (4.85%) as compared to six and a half percent (6.5%) only months ago. The difference can be significant in the monthly payment, which generally corresponds to the price a buyer is willing to pay. Second, concessions continue to inflate values and even the word “concessions” is a misnomer. We often find that either the listing price is increased to cover the concessions or the price is not decreased as much as it would have been without the concessions. This means that the seller is not conceding anything. Rather, the seller is trying to give away something that he or she does not own to begin with all at the expense of the lender, which ultimately may become the expense of taxpayers.

Unfortunately, concessions are still “business as usual,” so comparable sales are often inflated by approximately two to five percent and appraisers are expected to go along with this madness. Our company does not go along with it and unless the value is definitely there, without a question whatsoever, our appraisals do not reflect the “thin air” of concessions. It would be wise, I think, for every lender not to allow contracts that give money to the buyer if they do not want to perpetuate the problems we are currently experiencing. If the price the seller receives is to be lower, let the seller reduce the value accordingly instead of trying to give away something that the seller never had to begin with.

How Much Do I Get if I Buy a House?
We recently had some no-money-down sales with concessions which, when coupled with the $8,000 tax incentive, effectively paid the buyers $15,000 to buy the homes. What happens when interest rates go up and some buyers are laid off and cannot afford the payments? The buyers have no investment in the property, so they are quick to leave, and the result will be more of the same economic problems that are already debilitating our economy.

Appraisers on the Hook
Appraisers cannot control the bad lending practices which allow buyers to purchase with no money down. However, appraisers need to realize that every appraisal is a lawsuit waiting to happen, particularly if the property is foreclosed upon. Right now, there are companies offering to look at foreclosed properties to see if anything can be recovered from appraisers or their errors and omissions insurance. They review the appraisal to see if there are any flaws that might be grounds for litigation. Consequently, if concessions are part of the contract and the appraiser values the property including them, the appraiser should be certain that the valuation backs up the increment of value that the concessions include. Otherwise, the value of the property should only be the net amount - the actual amount that the buyer is paying. Other issues might be if the appraiser does not use REO or short sales, when they obviously affect the market, or if there are more recent comparables that were not used, which would have brought about a lower value conclusion.

Sale Price as Evidence of Value
The sale price of the property, according to case law in many states, is extremely convincing evidence of the property’s value. Therefore, it is legally proper that appraisers consider the “real” purchase price when analyzing a sales contract. There is a mindset among some appraisers that it is their job to make a transaction work but nothing could be further from the truth. Rather, the appraiser has the responsibility to protect the lender and him or herself. Recently, we were accused of being “mean” because we did not “bring in the value.” The owner could not understand why we would not allow the sale price. We explained that we are personally liable and may have to pay the difference if our value is inaccurate. Remember, the owner and the lender will not be there to help you if you are sued. If fact, they probably could not care less; they simply want their loan. You may even believe the sale price or refinance request is reasonable but if you cannot unquestionably prove it, do not “stick your neck out.” A good test is this: For every appraisal you perform, imagine yourself in court trying to explain why the value is accurate, and if you cannot, reduce the value until you can. One lawsuit can drag on for years and may be the end of an appraisal career if a license is revoked or if errors and omissions insurance can no longer be purchased or purchased at a reasonable cost.

U.S. Debt Affects Market Values
As lenders continue with their “madness” it is particularly important that appraisers protect themselves from liability and also become an instrument for stabilizing the real estate market by not continuing the bad practices of the past. Since the United States has increased its debt, which is financed through borrowing from the sale of bonds to other countries, it is quite probable that interest rates, at some point, will have to increase to continue to attract those funds. That increase will affect mortgage rates, which will effectively lower market values (remember people buy based on the payment), which may lead to more foreclosures and more scrutiny of appraisals. Since appraisers are charged with determining the present worth of future value, understanding these economic issues is part of the appraiser’s responsibility.

With HVCC implementation only days away, anger is turning to resignation and determination as appraisers seek ways to cope. One positive development is recently enacted legislation in three states regulating appraisal management companies (AMCs). Similar legislation is under consideration in 14 states. Find more below. 

If you are still formulating your position on HVCC (Home Valuation Code of Conduct), you will find a critique of the Code from the National Association of Realtors (NAR) at WorkingRE.com. In a letter to Fannie Mae, NAR President Charles M. McMillan, CIPS, GRI , requests that implementation of the Code be delayed for several reasons, including what he sees as a lack of guidance by Fannie/Freddie on how to implement the Code. “Neither of the government sponsored enterprises (GSE), Fannie Mae or Freddie Mac, provided substantive guidance on implementation until weeks before the effective date of the agreement. The Federal Housing Finance Agency (FHFA) has been silent on the agreement since the announcement late last year,” McMillan said.

The letter sites other grounds for delaying implementation, including that HVCC does not apply to FHA transactions; AMC regulation is underway in many states already; HVCC may increase the cost of real estate transactions; lenders are not prepared for HVCC and the proposed enforcement agency set up by the Code is not functioning yet (Independent Valuation Protection Institute). Find the letter at WorkingRE.com, Sidebar: NAR’s Letter to Delay HVCC.

HVCC Talkback Blog
Speaking out on the OREP/WRE Talkback Blog, appraisers continue to rail against what many see as an unfair intrusion into their businesses and point out that the “fix” - increased prominence of AMCs, may worsen the problem HVCC set out to improve- appraisal quality. Some appraisers, of course, say they like working with AMCs and support the Code because the unrelenting pressure had to stop. Some point out that the HVCC is not law but only a private agreement between the New York State Attorney General and Fannie/Freddie. Others remind us that appraisers are still eligible for direct assignments from brokers and non-lenders for FHA assignments.

There is also activity on the “Appraiser Rater” section of the Blog, where appraisers provide feedback on working with specific AMCs. The staff of several defend their companies, insisting that not every AMC considers low fees first in appraiser selection and not every one disregards or diminishes the role of appraisers; it’s unfair to paint every AMC with the same brush, they say.

Many appraisers continue to call for cohesion in the ranks and suggest a nationwide “walk out” to demonstrate the importance of appraisers in the process. Most continue to insist that they can not and will not work for half fees. Find a link to the Talkblock Blog and Survey below. We encourage every appraiser to make his or her voice heard by participating in the survey. It is the only way to find out what is really going on. 

Unreasonable User Agreements
To make hard times harder, appraisers are facing new, more unreasonable user agreements that attempt to shift liability from the AMC/entity to the appraiser if anything goes wrong with the loan, no matter who is at fault. Appraisers must sign these agreements to continue working with the AMC.

One agreement contains a “buyback” provision where the appraiser: “agrees that if a mortgage lender is required to repurchase a mortgage loan for any reason in any way related to [among other things] . . . any appraisal report submitted by Appraiser pursuant to this Agreement, Appraiser shall pay [AMC/Entity] an amount equal to the repurchase price paid by such mortgage lender to repurchase such mortgage loan.” The appraiser is further required to “pay the reasonable attorney’s fees of [AMC/Entity] incurred in enforcing Appraiser’s obligations hereunder, including, with [sic] limitation, the obligation of Appraiser to pay [AMC/Entity] an amount equal to the repurchase price of a mortgage loan as set forth above.”

Not much has changed since WRE broke this story last Fall: signing these agreements does not abrogate an appraiser’s own E&O insurance coverage; it remains in place. However, E&O insurance does not typically provide coverage for third parties, such as an AMC. If an appraiser agrees to hold an AMC harmless, they will be bearing the cost out of their own pocket. This makes any such agreement a (very difficult) business decision; is the continued work from the AMC worth the increased liability burden? Many appraisers say it is not; agreements such as this one are potentially “game enders” for appraisers should they be held to the terms. Even the most careful appraisers say they will not sign because it holds them accountable even if they are not at fault. See FNC-Appraiser Firestorm (Again) at WorkingRE.com, Library, Volume 20. 

Industry Fights Back: AMC Regulation
Legislation to regulate appraiser management companies has been signed into law in three states (UT, AR, NM), including two Bills recently passed in Arkansas. The legislation in all three states are similar in intent (more in the next print edition of WRE).

The Arkansas legislation requires that AMCs register and put up a bond to ensure that appraisers are paid (Act 628 of 2009). There also is language prohibiting Broker Price Opinions and making the coercion of appraisers illegal (Act 413 of 2009). According to Tom M. Ferstl, MAI, SRA, Executive Secretary of the Arkansas Appraisers Association, there is strength in numbers, at least in Arkansas.

“With the growth of the Arkansans Appraisers Coalition, we were able to hire an experienced lobbyist who was able to get the support of key legislators and point us in the direction we needed,” Ferstl said. “Thus, with passage of legislation outlawing the use of BPOs in lieu of real appraisals, we are in a position to reverse the trend of recent years against the independence of professional appraisers. If you read the Act closely you will see that we gave the Licensing Board the option of filing criminal charges against real estate brokers who even advertise to perform BPOs in the area of mortgage lending.”

Ferstl says his group fought hard to ensure that the Arkansas Bill fell under the authority of the Appraiser’s Board and not another entity that might not have appraisers’ best interests in mind. Find Arkansas Acts 413 (Appraiser Independence) and 628 (AMC Registration and Regulation) at WorkingRE.com, Sidebars.

In Appraisers Fighting Back (WorkingRE.com, Library, Volume 17) you can read more about a previous AR bill which restricts Broker Price Opinions (BPOs) from being “treated like appraisals.”