Sunday, December 6, 2009

7 Reasons to Regulate Appraisal Management Companies in Florida


Thanks to Representative Matt Hudson, a bill has been introduced in the Florida House of Representatives to regulate Appraisal Management Companies (AMCs) in Florida. Representatives Peter Nehr and Ritch Workman have agreed to cosponsor the bill!
Since the introduction, some folks have been wondering why there is concern. Why is it necessary for more regulation? Shouldn't government just butt out and let the market sort things out?

For a start, here are 7 reasons to regulate AMCs in Florida:


  • Appraisal Management Companies are not regulated in Florida

  • Since May 1, 2009 and the implementation of the Home Valuation Code of Conduct (HVCC), a majority of Appraisal Assignments are placed through Appraisal Management Companies

  • There is mounting evidence of Appraisal Management Company interference with Appraiser Independence including pressure to decrease or increase opinions of value, exclude or include specific comparable sales, and make specific adjustments to comparable sales

  • There is mounting evidence of Appraisal Management Company alteration of Appraisal Reports and Appraisal Review Reports

  • There is evidence of Appraisal Management Company ownership and management by individuals with Division of Real Estate disciplinary history or criminal records

  • There is evidence of AMC use of unlicensed individuals for appraisal review

  • There is a lack of transparency to the consumer with respect to appraisal fees and appraisal procedures and a need to protect the public from wrongdoing and disregard for appraiser independence

Let's take a look at the recent job posting for a "Quality Control Reviewer" by StreetLinks. This same job title was advertised back in August, 2009. The link is no longer live, but Appraiser Active discussed the job and StreetLinks in THIS post back then. It appears as though the duties and qualifications have not changed much. The only difference is now a college degree is "preferred" and candidates are Candidates are "required to take and pass the National USPAP Equivalency exam after 90 days of employment and continued education courses are required every 2 years or as the industry dictates."

Sounds GREAT eh? Here are a few more details about the position culled from a posting by a StreetLinks suit:


These are W-2, hourly positions at approx $17/hr plus insurance benefits and continuing education reimbursement. Opportunity for advancement into escalated reviews, appeals, and management.Involves performing an underwriter-style review of appraisal reports with an emphasis on evaluating the appraiser's approach to their value conclusion. StreetLinks' QC reviews take 35-40 minutes on average.

The post cited above is directed to "licensed appraisers". This was the first line:

StreetLinks National Appraisal Services is seeking an additional 30 licensed appraisers for our quality control department in southern Indianapolis.

Does it look to you they intend to use either licensed or unlicensed folks to review appraisals completed in all areas of the country? Does it appear to you these reviews will be done in Indianapolis, Indiana? Is there any license requirement listed in the qualifications? Which state?

Just in case the link disappears, here is the offering.


Quality Control Reviewer - Multiple Openings - Job - Street Links Jobs

Florida is not the only state interested in regulating AMCs. Take a look at a recent article from Oregon. The same reasons for regulation apply there, although the article concentrates on another aspect Appraiser Active has addressed previously; stiffing the appraiser on his fee. Here's a couple of excerpts:


Unlike appraisers and mortgage brokers, AMCs are not regulated in Oregon. Their wwners and employees are not required to undergo background checks. The companies are not required to be licensed, bonded or insured.

Solitz, for his part, says he has a good example of the need for new rules: an AMC that appears to be the target of a criminal investigation, one in which Solitz is a complainant.

Solitz has been waiting two months to be paid by Valuation Logistics, a Portland-based AMC that does business with appraisers across the country.

According to an online appraisers forum, some are urging people to share information with Portland police based on reports of appraisers not being paid by the firm. Solitz is one of those cooperating with authorities, saying he has received two phone calls from a Portland police detective in recent days. The detective, Liz Cruthers, declined to comment.

The Better Business Bureau has rated Valuation Logistics with an “F,” or failing grade, citing four complaints involving billing or collection issues that the company either did not resolve or did not respond to.

Public records also show that staff of the agency that regulates Oregon appraisers, the Appraisal Certification and Licensure Board, has brought Valuation Logistics to the attention of the board’s appointed members. Of particular interest was that Olson co-founded the company with a Portland appraiser who has had several run-ins with the state board.

In April 2009, the board suspended that appraiser, Nathan Bernhardt, for six months based on nine violations of appraisal rules.

Asked about Valuation Logistics, Bernhardt said he is no longer involved in the firm but declined to otherwise comment. Other past business partners of Olson also declined to comment.

Public records show that Olson has been involved in other companies before going into the appraisal management business. He also has been under law enforcement scrutiny in the past, including an arrest in Clackamas County for contempt of court in 2007.

In 2005, in an unrelated matter, his participation in a Wilsonville manufacturing firm called Medium Build ended when his two partners accused him of embezzling more than $50,000 as well as transferring a company vehicle to a friend of Olson’s without permission, according to a Clackamas County Sheriff’s Office report.

Why do AMCs seem to attract the "best" in society? Just askin'.

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