Virginia Regulatory Town Hall
Agency
Department of Professional and Occupational Regulation
 
Board
Real Estate Appraiser Board
 
chapter
Real Estate Appraiser Board Rules and Regulations [18 VAC 130 ‑ 20]
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5/16/08  11:12 am
Commenter: Donald H. Kinum Jr., ATLANTIC Associates

Electronic portal transmission of appraisal reports.
 

Recent interaction with several banking clients indicates to me that the banking industry is in a state of denial regarding their responsibility for the credit crash brought on by their predatory lending practices.  The interaction that I am seeing is one of continued haughty arrogance resulting in a "business as usual" attitude, particularly toward the appraiser.

It is quite clear, that the requirements of USPAP preclude the use of any means of removing signatures, doctoring or otherwise manipulating data, and re-affixing signatures as if nothing had happened in between.  If this was done manually with white-out and typewriter or pen, there would be no question that a crime had been commited for personal gain.  It would fall under the laws pertaining to fraud, forgery, grand larceny, embezlement, conspiracy to defraud and others.  I'm sure a prosecuting attorney could think of a few more charges.  I sometimes wonder if the banking lobby and the politicians they seduce could be prosecuted under the RICO statutes!

The requirements of USPAP and the use of electronic portal transmission of reports are mutually exclusive.  They cannot co-exist as currently utilized.  To rationalize such a situation is to make a mockery of the law and foster contempt for those in leadership positions who allow such nonsense.

Everybody says they want independent appraisers to provide unbiased estimates of value, but nobody is willing to stand up against the banking lobby give us independence.  Because of the recent excesses in the lending industry, we have a window of opportunity to do something good.  Windows of opportunity never stay open indefinitely.  Please support the petition.  Thank you.

 

CommentID: 1493