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Notes from Regulatory Road: REVAA’s Perspectives on Appraisal Regulatory Issues 

Jeff Dickstein, Pro Teck’s Chief Compliance Officer, is responsible for Pro Teck’s adherence to all state, federal and industry regulations. With Notes from the Regulatory Road, Jeff provides timely commentary on what is happening in the industry.

Last month saw myself and Thomas Hoff, Pro Teck’s VP, Marketing & Communications head to the nation’s capital for a day of “fly-in” meetings on Capitol Hill.

Pro Teck, with colleagues from the Real Estate Valuation Advocacy Association (REVAA), met with the staff of more than thirty legislators to discuss topics important to our industry.

I was with a group that met with representatives from the following D.C. lawmakers:

  • Congressman Steve Pearce of New Mexico
  • Senator Thom Tillis of North Carolina
  • Senator Heidi Heitkamp of North Dakota
  • Congressman Michael Capuano of Massachusetts
  • Leader Senator Mendoza of New Jersey
  • Senator Brian Schatz of Hawaii
  • Senator Bob Corker of Tennessee
  • Senator Elizabeth Warren of Massachusetts
  • Senator John Kennedy of Louisiana

While there is no imminent legislation impacting the appraisal industry, we offered to provide assistance in the future when any type of reform is debated. We also discussed:

  • H.R. 10: The Financial CHOICE Act — This legislation currently does not include any adverse language related to repealing parts of Dodd-Frank related to AMCs, residential appraisal or appraisal independence. Word from the Senate is that the most likely scenario is that several non-controversial parts of H.R.-10 might be spun off as smaller, stand-alone bills.
  • Federal Appraisal Regulatory Authority — AMCs are not federally regulated. The Appraisal Subcommittee oversees state appraisal AMC regulatory systems to ensure compliance. While several appraisal regulatory reforms have been suggested, REVAA believes any reform must include a federal backstop, such as the subcommittee, to ensure there is consistency among state regulatory schemes. REVAA’s position is that it supports this regulatory structure, with modernization to improve functions moving forward.
  • Appraisal Shortage/Trainees — REVAA believes the immediate shortage of residential appraisers is largely an anomaly caused by an increase in demand for appraisers. Although it appears the strain has since eased in most of the country, there are some markets (primarily in rural areas) where a shortage of appraisers does exist. REVAA is concerned by the lack of “next generation” appraisers entering the profession and supports The Appraisal Foundation’s (TAF) efforts to reduce barriers for entry. Additionally, REVAA supports working with TAF to develop best practices for AMCs to supervise trainees.

Something to Keep an Eye On

The Federal Trade Commission (FTC) announced May 31 that it has filed a complaint against the Louisiana Real Estate Appraisers Board, alleging the group is unreasonably restraining price competition for appraisal services in Louisiana, contrary to federal antitrust law. Pro Teck will continue to monitor this situation, and as always will make sure our clients are compliant with all state and federal law.

Jeff Dickstein, Pro Teck’s Chief Compliance Officer, is responsible for Pro Teck’s adherence to all state, federal and industry regulations. He’s active with a number of industry boards and is currently Chairman of The Appraisal Foundation’s Industry Advisory Council.

Jeff has been in the mortgage industry for 36 years, with more than 29 years of experience as an appraiser (he is a Certified Residential Appraiser in 17 states). With Notes from the Regulatory Road, Jeff will provide timely commentary on what is happening in the industry.

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