September 3, 2019 – As promised a month ago, The ASB has issued their concept paper with ample time for everyone to comment. Also, there will be a webinar on September 10th and a public meeting on October 18th.
The concept paper can be found at:
If this URL is too long, go to the Standards & Qualifications tab on TAF website.
After reading the document, I believe it is well explained and gives everyone a chance to opine. I think a statement or two are slightly misleading, but they explain why they say what they say and that is just fine. If I am up for it one day, I might add a post here listing out the items I disagree with.
My stance will never change. Evaluations need to stay outside of TAF. Just leave this product under the domain of federal regulators who actually do have the power to go after anyone who performs fraudulent evaluations. The federal regulators have enforcement power that TAF and ASB do not have.
Please take the time to send them your comments. They do read everything they receive. Obviously, some meat to your stance will carry more weight. Try to give some factual information. Simply saying evaluations are more risky is factually wrong. People like myself that have ordered and reviewed appraisals and evaluations on all property types, performed due diligence on dozens of good and bad banks, et al, know loans allowing evaluations are, and likely always will be, less risky than loans requiring appraisals.
Unlike our politics, it will help if you don’t say you are a Never-Evaluations person and leave it at that. No need to call each other Appraisalphobic or Evaluationphobic lol
Give the ASB some real substance and they will give your comments significant weight. Give them suggested wording and they will consider it.
Just saying ‘because’ is what a 5-year old says:)
Take advantage of your chance to comment…