Should Property Data Collectors Be Licensed?

Should Property Data Collectors Be LicensedShould “property data collectors” who inspect properties and provide information to real estate appraisers be licensed by state appraiser boards? In Mississippi, a bill has been introduced this week to require exactly that. The legislator behind the bill happens to be an appraiser.

HB1663 would establish a license category for property data collectors under the jurisdiction of the Mississippi Real Estate Appraisal Board. A property data collector would be defined as an individual or company, who is not a licensed appraiser and “who collects, either physically, virtually, or digitally, any information on real property, and produces such information to a licensed real estate appraiser who uses it in the course of forming an opinion of value.” Under the bill, it would be unlawful for any party to act as a data collector without an appraiser license or property data collector license. As introduced, and being the first proposed legislation regarding property data collectors, the bill is perhaps “rough around the edges.” For example, the proposed definition of property data collector might include sales data information providers. The present bill also refers to requirements for data collectors established by the Appraiser Qualifications Board, which do not exist.

If you’d like to know about other relevant legislation pertaining to property valuation, take a look at my legislative map on which I highlight some of the bills I am following for my clients.

Bill Summary

An act to authorize a person licensed as a property data collector to collect data for real estate and real property in the state of Mississippi for the purpose of providing such data to a licensed real estate appraiser who uses the data in the course of forming an opinion of value for an identified parcel of real estate or identified real property at a particular point in time; to require that applications for a property data collector license, application for renewal, and application to take an examination shall be made in writing to the Mississippi real estate appraisal board; to provide certain requirements for applicants to qualify to be a licensed property data collector; to require that an applicant be successfully cleared for licensure through a background investigation to qualify for a Mississippi property data collector license; to require licensed property data collectors to obtain errors and omissions insurance in an amount that is no less than the coverage required for licensed real estate appraisers; to require licensed property data collectors to complete twenty-eight hours of continuing education for renewal of a license; to require a licensed property data collector to retain for a period of five years the original or a true copy of each property data collection report prepared or signed by such property data collector and all supporting data assembled and formulated by the property data collector in preparing each such property data collection report; to amend sections 73-34-3, 73-34-5, 73-34-9, 73-34-43, 73-34-47, 73-34-49, 73-34-51, and 73-34-55, Mississippi code of 1972, which relate to licensed real estate appraisers and the Mississippi real estate appraisal board, to conform to the preceding provisions; and for related purposes.

Peter Christensen
Image credit flickr - pedro layant
Peter Christensen

Peter Christensen

Peter Christensen is an attorney, licensed in California and Washington. His legal practice primarily serves the real estate valuation community - Valuation Legal. He's the author of Risk Management for Real Estate Appraisers and Appraisal Firms, published by the Appraisal Institute.

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63 Responses

  1. Avatar Dave says:

    Not our decision to make – Ask Lyle Rieke at FANNIE!

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  2. Avatar Dana says:

    Love this!

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  3. Avatar Loidene says:

    Would the Property Data Collectors then be held to the ANSI standard of measurements which Fannie requires of the Appraiser’s actually measuring a property? Seems very interesting that Fannie changed the rules to meet their narrative!

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  4. Geez! Is it me or is this just plain nuts! Great that they want PDC’s to be licensed but hey people Appraisers are already licensed, we already collect data and form an opinion of value. Why have 2 people do what 1 person can do? Is it all about saving money or because of all this bias crap, keeping the Appraiser from seeing the homeowner? What a joke. I for one will never complete an appraisal where a PDC is involved. Why would I? I don’t want that liability. Now with this proposed licensing requirement, I guess they could be held liable if they do not provide correct data or God Forbid they apply bias. Then we can all blame the PDC not the Appraisers for Bias! Hey maybe we are on to something. Take the heat off us and place it on the PDC since they are the ones who meet the homeowner. Or will they still blame us since we report the actual value number and select the comparable sales. This whole thing has gone so far off the rails! Makes me sick.

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    • Avatar Sadie says:

      It is just another way for the government to make more money. I would not be in favor of something like this. If there are those who would like to have a person to do this work then check their backgrounds very carefully and hire retired Appraisers and/or Realtors. After all they have been in the business for a long time and know what data an appraiser needs. But government control is not the answer.

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  5. Avatar Tobby says:

    Be careful what you ask for. A license for the PDC would give them legitimacy. It would remove two of the primary reasons against their use. 1. Realtors won’t let unlicensed persons into a house, and are somewhat concerned about the liability if the buyer overpays for the dwelling only to sue them down the road. 2.Lenders whom are still liable (rep and warrant) for disclosing the condition of the house, and would rather have an appraiser’s E&O to fall back on. A license which might require a background check, a bond or E&O insurance might alleviate those objections. If the license were difficult to obtain it would impact the cost greatly (no pizza delivery drivers). However, if the license was little more than a rubber stamp with no educational or competency testing then it would take away those objections, and likely result in an increase in their usage.

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  6. Avatar Mark Zeigler says:

    I am all for improvements, but this does not fit. I will never trust a PDC to do anything correctly. I will sign only what I inspect and collect. Worked for 45 years, it will work for a few more….
    Appraisers inspecting the subject is not broken, nothing to fix.

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    • Baggins Baggins says:

      The legislative proposal highlights the need for property data collectors to posses a certain level of accountability and skill. Specifically what the competent field appraiser already has. So why shouldn’t they be held to a similar if not mirrored regulatory oversight. Let’s do individual licensing for every single amc employee next.

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    • Avatar JohnWelter says:

      I’m at this game for 42 years. I agree with you 100%. This whole concept of PDC’s is a true slap in the face for appraisers. The process will become so disjointed that more time is going to be spent explaining misinformation, more addendums, more liability, less accuracy for sure, and I will never be a part of it.

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      • Avatar Russell says:

        You are 100% correct.

        I received an email from a client telling me “my gla and condition did not match with the other data they have access to other than public records.” I told them “I do not know anything about that because I personally inspected the property, measured or verified my data.” I told them to call the people that you got the data from and question them.” All of my reports have a comment on how I collect and verify my data and if they had thoroughly read my report they would known this.

        The lenders, amcs, fannie mae, fha, va, etc. have access to property data that they will not allow us to access. Why I do not know? We should have access to that data too.

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  7. As stated before, we don’t need two people to do what one clearly can do. And, why not simply allow appraiser trainees to do this? This way, nothing has to change except to allow the trainees to do this. They already have been fingerprinted, have E & O insurance, already have continuing education, my goodness we need to stop trying to reinvent the wheel.

    The answer to this mess is just let us Certified appraisers work as independent appraisers regarding lending transactions. Period. Thats it. Very simple. We can handle this quite well without anyones help.

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    • Avatar GKBNM says:

      Frustration by over regulation to eliminate the appraiser in the entirety.

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    • Avatar Russell says:

      You are correct! Trainees would be perfect for this. None of the amcs I work with will not allow trainees to inspect the property without being accompanied by a higher licensed appraiser. When they started this it did not make sense then and it does not make sense now.

      This is one of the very reason I do not have any trainees. Why would I go with a trainee on every inspection after a few inspections to make sure they knew what to do? Why would an appraiser that could be getting full fee be out with a trainee all the time?

      When I was a trainee or registered appraiser in my state no one ever went out with me. I did it by myself and my supervisory appraiser signed off on the appraisal because they knew I did my due diligence to understand and know what I was doing. If I had any questions or doubts they would assist me as needed.

      To this day when I am stuck on an appraisal or sometimes become too analytical I call two of my friends to discuss my problem and they always put me on the right track.

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  8. Plus, don’t forget, they still work for the BANK…

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  9. Avatar Russell Bean says:

    Does everything require a license? Does everything have to be government controlled? It is not rocket science to be a property data collector and surely does not require a lot of skill.

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    • Avatar GKBNM says:

      It’s not as simple as that. It’s about exposure to the appraiser for something he or she can’t control. The appraiser signs a statement that he or she accepts full responsibility for the report. That includes information provided by the data collector who the appraiser has no confidence they are or are not qualified. If someone, beyond the control of the appraiser such as a data collector screws up and the appraiser gets called out on the carpet, he or she can lose their license and/or be sued. It takes a lot of skill. The data collector should have the same or better data collection skills than the appraiser and that comes with training. So yeah, I can think of lots of reasons to not deal with that. If your comment was “tongue in cheek” I’m not sure but this is a passionate issue for me.

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      • Avatar Russell Bean says:

        We use data everyday this is not our first hand data. Meaning we did not put our eyes, hands on it or we did not gather the data first hand. If we believe the data is credible and reliable source we use it. I verify the data I put use and put into my reports. I call sellers, buyers, Realtors, Tax Assessors, government offices etc. I have knocked on doors and asked buyers about their property with the mls sheet and tax assessor records in my hand if i have any doubt about the information. If I cannot verify it I will state it in my report or most likely will not use it depending upon what it is.

        A data collector will not know what I am looking for and would not use their information unless I could verify it and be able to talk to them

        Yes, you are right bottom line we are fully responsible for our reports. So, personally requiring data collectors be licensed is a waste of time. My opinion may change in the future.

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    • To be a good data collector requires a high level of skill. The Appraiser is required to measure to ANSI Z 7652021 measurement standards. I have 34 years experience and still have to get the ANSI book out sometimes to decide how to treat some areas of a house. The person that came up with the Data Collection idea had no idea of the skill level of a good Appraiser. My guess is someone wanted to speed up the process when rates were low and appraisal demand was high.

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      • Baggins Baggins says:

        Or one could turn to the local jurisdictions building codes on valid square footage, as the builder reported them to the county, as the county recorded them with the assessors, which the local MLS and sales ages are supposed to be using as the main reference for home sizing.

        Or just come up with a totally different system that nobody else in the area uses.

        ANSI was a GSE gift to the green building code community, whom sought a standardized measurement recognition for federal contracts and subsidies. As well as being convenient for people whom struggled to perform simple math calculations with inches rather than tenth scale metric.

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  10. Avatar GKBNM says:

    Is that a question? You should take your career to the next level and start a class action lawsuit. There are plenty of things to pick from in the appraisal industry except competent representation. You will surely have adequate support I have no doubt. Dave above has a very accurate response all kidding aside. The oligarchs have all the say. The appraiser is insured to the hilt and, so what if the contracted data collector screws up, we will have the appraiser on the hook…”shut your mouth” that can’t possibly be true? I took liberties with the movie “Shaft” theme song. Speaking of “Shaft” that is exactly what the appraiser will get when the unlicensed, uninsured, uncredentialed data collector will get when they screw up. Some of the regulations coming out of FNMA (a government endorsed, publicly traded, private company) are in direct conflict with appraiser legal requirements, yep, no kidding. But we don’t hear any grumbling from the Appraisal Institute, do we? Where are they? You members should all bail instead of paying those hefty salaries and for that premium office space they have. Hmm, if I perform heart surgery with no formal training, unlicensed and uninsured and the patient dies will the surgeon who I was assigned to be liable? Little over the top but you get the idea. Well, it’s no different than what they are asking of the appraiser. We sign off on the assignment guaranteeing the report is correct. What kind of person does it take to actually require, not even suggest, this kind of exposure to another human being just trying to make a living? A number of years ago this would be laughable. Mankind is in huge trouble, folks.

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  11. Avatar Dave says:

    Russell give us a break, he spent too much time, calling up people and asking for their hearsay opinions on unverified data. Use the raw data you have and stop relying on unattributed opinions that are rarely based in fact, but based on peoples memories. That is not what we get paid to do. Take the raw data analyze it and don’t take third-party hearsay, bad habit!

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    • Avatar Todd Redington says:

      Dave, so what you are saying with this
      *****Take the raw data analyze it and don’t take third-party hearsay, bad habit!****
      is that for 37 years I have been wasting time calling every listing/selling agent on my comparable sales?
      How do you verify the terms, conditions and motivations of the participants to the transaction?

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  12. Avatar Russell says:

    Dave, I do not need to give you or anyone else a break because I am telling you what I do. The raw data in my area is often flawed. The MLS and Tax Assessors information leaves out a lot of important information to me.

    The realtors do not count gla like we do, the tax assessors do not go into the homes and often miss additions, my mls does not list closing cost, contract date and they lump basement with total gla. Realtors forget to change pending to sold, Realtors sometimes have two active mls listings on the same property, Realtors do not put on the mls why the property sold for more than list price etc.

    So, tell me how is it third party hearsay when I talk directly with the buyer, talk with the listing or selling agent who was part of the deal, talk with the tax assessor who is putting the data out they use?

    I also record in the file who I talked with, the date, the time and what was said.

    Maybe your raw data is much better than mine. I do get paid for what I do. I do not do charge low fees because I do not have to.

    I take the saying “trust but verify” seriously. My method has worked very well for me for over 2 decades in my appraisal business. I have a proven reputation for being very thorough. Even with that there is no perfect report.

    I feel for me it is “better to be safe than sorry.” It is risk management. I have used this method in my other four businesses for almost five decades and it has not failed me yet . My bank accounts agree with me. This is a character or habit I live by.

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  13. Avatar Dave says:

    This is really simple, please listen to me! You are required to include in your report that you are complying with ANSI measurements. Neither you nor any of your contemporaries, nor any of your data sources are. Back to basics, use the best data you have and do not rely on casual conversations with your friends; that is foolish! Just footnotes!
    D

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    • Avatar Russell says:

      I have always used the ANSI standards on every subject I have inspected for over 20 years. Again, I am talking about data that I did not create first hand.

      Also, I have always taken pictures of all exterior sides, roof, exterior buildings and structures, crawl, attic, every interior room except closets unless I see something strange. Also, any deferred maintenance that matters. My report have more pictures than the average appraisal.

      So, when lenders started requiring many of these things I was already doing them.

      Sure, it may be an overkill. It will come in handy if the officials come a knocking, if you know what I mean?

      Also, being a paralegal that specialize in real estate and ligation for 38 years makes me this way too.

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      • Baggins Baggins says:

        So, you’re saying this is a better career choice than lawn mowing?

        I’m sorry, I could not resist. Oh wow did you know about this? There is an entire series of lawn mowing patches and vehicle stickers for sale online. Ummmm… Something really important just came up, have to run. Thanks.

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  14. Avatar Dave says:

    Hey Russell, come on down from your high horse. All single-family residential measurements are required to be taken from the outside. ANSI is to the 1/10 of an inch. So do you mind introducing all of us lesser non-paralegals to where you buy your stepladder to walk around the outside of the 2nd floor of the house so that you can comply with ANSI to the 1/10 of an inch? Please don’t patronize us with your foolishness.

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    • ANSI is to a 1/10 of a foot, not 1/10 of an inch. You can measure the upper level from ground level, sometimes you need to go around the outside of the house more than once to make sure you get both levels measured right. I also take some inside measurements, not as easy as you think to get it right.

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      • Baggins Baggins says:

        The concept is not logical, co mingling two entirely different measurement standards. Mandating metric, but only after the foot. Otherwise, standard feet is acceptable. But not acceptable for anything less than a foot. How long before they drop the foot and go with the meter instead?
        Pop quiz, what is one tenth of one foot in inches…

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  15. Avatar jaydee says:

    When it comes to measuring, viewing, stating facts I know about a property; I trust me before anyone else. I don’t trust Realtors to correctly measure and report (they use to but now rely on the assessors), assessors (they don’t measure either), blue prints – many areas that shouldn’t be counted are. If you all go along with this, you’d be opening yourself up for a lawsuit and/or complaint. TRUST NO ONE but yourself. THEY’LL HOLD YOU RESPONSIBLE. REJECT THIS NONSENSE!!!

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  16. Avatar Russell says:

    Ok Dave, not on a high horse. I never told you or anyone else what to do or how to do it. I simply shared what I do and why.. Take from it whatever you please or not. I never attacked your ability or told you or anyone else that you were doing anything wrong. I do not apologize for how I run my business. However, I do apologize for offending you or anyone else for whatever reason . That was not my intention. Peace!

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    • Baggins Baggins says:

      Appraisers conversing about unreliable MLS data should turn to the Realty boards which govern the MLS instead. Some of the better managed MLS systems have firm rules and a complaint submission system in place. If agents fail to update listings within a week, fail to correct flawed data or somehow not disclose uncertain or altered data, they receive scaling penalties from the MLS agreement terms. A series of warnings, fines, larger fines, probation, temporary suspension, permanent suspension. Gives them a chance to change the approach and perform the duty correctly. Fines can be steep, more than a years worth of the MLS subscription costs. There is no excuses, or claiming ignorance as they clearly progress through the internal penalty matrix, and the MLS team has a system to devote investigative manpower to all complaints received. If any corrective action for data integrity is necessary, that should be directed at the MLS systems management, not the appraisers methodology.

      Such a process of effective oversight is not present with PDC’s and amc’s, nor will one ever exist outside of licensing the individuals or some better oversight. This deal with ‘lenders must maintain oversight of third party companies they work with’, is simply not working. Wholesale lenders work with basically every single amc out there, at the same time. Impossible for them to have effective oversight of the amc process. PDC’s would represent a fourth and fifth party service, even further detached from the possibility of effective oversight. Audit amc’s nationally, none of them are compliant with everything they should be compliant regarding. Every single one of the amc’s bend or flex some rule or guideline, in order to advocate for the lender client, retain, and capture, more appraisal processing volume.

      Appraisers may rely on fifth party property data collectors if they want to. When it comes to the default management or field review process, the data won’t hold up, the ordinary assumption will appear unreasonable, complaints will be filed. Alternatively; Using an extra ordinary assumption for every single report, as they would all rely on PDC data, is arguably a violation of professional standards. Outside of the appraisal world, no reasonable or logical person seeking accountability will buy into that approach as legitimate. One look into the PDC’s persons work or criminal history, a few competency quiz questions on the stand, the appraiser will be the one left holding the bag. The neat part is that will be the first time the appraiser gets to know whom the PDC person was, the moment after their credibility is destroyed.

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      • Baggins Baggins says:

        Hopefully this link will work for you without the MLS login. Section 22. MLS rules and regulations. What you see below, is something of a long term collaboration effort, as metropolitan MLS’s eventually combined, shared data, and adopted each others more meaningful guidelines.
        https://cdn.recolorado.com/files/MLS-Rules-and-Regulations.pdf

        The PDC system is a side step to existing regulatory guidelines. When realty agents complete PDC services in leu of the appraiser, the agent enjoys a virtually unregulated environment, as their ‘inspection’ services do not fall under their licensing scope, because they’re not acting as realty agents. The next obvious progression to avoid oversight; use unlicensed people. Enter the PDC program. Cheaper. Faster. No industry experience to even recognize they may be participating in fraudulent or predatory systems. They’ll never bug the people for listing opportunities either, which is the ongoing problem with subbing out appraisers for realtors today. Remember all the PIR’s and simple drive by’s which sustained the appraisal industry and allowed us to afford trainees? Realty agents complete nearly all of that today, or lenders skirt the duty of verification with value acceptance and waivers instead.

        The issue of PDC’s traces back to the larger problem that appraisers should never have been subbed out of those simple duties in the first place. When appraisers lost that work flow, the majority of appraisers also lost their financial ability to train new appraisers. We used to get $150 for every single PIR request, and decent lender clients would cut the appraiser out with about a 1/5th ratio of PIR’s compared to full service appraisal requests. Guess what; Amc’s kept the difference and still bill the lender those same amounts today, despite having driven the service fee down to something around ten or twenty dollars.

        The purpose of using appraisers for this service for the past three or more decades was accountability, as inspection and data integrity standards for appraisers had already been clearly defined. When amc’s sub out appraisers for someone else, that’s avoiding complying with existing regulatory guidelines. Removing the appraiser is not about helping consumers or saving anyone money. Removing the human appraiser is what allows fraud to go under the radar unrecognized. One should not talk about property data collectors without also talking about amc’s, because it will be the amc’s whom primarily use this service.

        These are among my last days participating in these conversations. The industry is approaching the precipice where either everyone rallies, or there is no point in trying to save it anymore.

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      • Avatar Russell says:

        This is great information. I wish that my MLS would take the data they give more seriously. I was a member of five MLS Boards. We do not have a one catch all MLS for the state. Example: my local board covers only four counties. I have to join the other Boards to cover the other areas I want to work in.

        My business is mainly rural areas about 50 miles radius. Each board have their own rules and they report data differently on their MLS. Some of the counties I cover do not have a Board of Realtors or MLS so I to use the old school methods along with internet data to determine what sales are arms length plus the other things we need to know to complete our reports.

        I would make request to report certain data that would make our jobs more accurate and easier. Some would make the changes and some would resist. Some would say we cannot do such and such. I would call Navica who host their MLS website told me “yes we can do that it just that the local board will need to request those features to be turned on.” I would call them back and tell them what Navica said. Some would do it right away or say we will add it on our next update or some would do nothing.

        My local board would do nothing and the other local appraisers complained about it too. One of the other MLS Boards would bill me an extra $200 each year for a State Board Fee and said “that I could not opt out because the state mls board required it. I asked them what am I getting for this fee? They said any state support or lobbying. I knew this was not true because I also hold a GA real estate agent license that is inactive and they never advocate for appraisers.

        I called the state mls board and asked them “why did I need to join the state board and what would I get for my fee?” They ran down a list of things and not one of them applied to what we do as appraisers there were absolutely not one benefit to me. This bothered me so I said “why should I spend money on something that does not benefit me at all?” She said “we do not require you to join.” I told her that local board said I had to pay the fee to at least one of the boards I was a member of.” She said “that is not true.”

        I called that local board back and told them what the state board said. Then they told me” well it is in our by-laws that you have to join the state board.” I asked her “what sense does that make since the state board only advocates for real estate agents and brokers and not appraisers?”

        I said “the board needs to reconsider this decision to amend their by-laws joining as an option and not a requirement since the state mls board does not require an appraiser to be a member.” After calling several time addressing my concerns it took them three years to make the change.

        Getting back to my local board who just billed me almost $700 has resisted doing anything about updating their mls for better data reporting and specific parameters searches we use even though they have the capability of doing so.

        So, when I find data that is wrong I call the listing agent or broker and inform them. Sometimes they make the change. I offered to do a class for the Realtors to share with them why accurate data is important and what data we need to make our reports as accurate and credible. They have not accepted my offer.

        So, I have to do a work around. I have built relationships with many of the Realtors and Brokers, the tax assessors , the Clerks of Superior Courts, probate offices, tax revenues, attorneys, zoning and whomever I need to verify data with. So, if it come down to that we have to use PDCs and I cannot verify their data then I will not be accepting any of those orders.

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        • Baggins Baggins says:

          Sure. MLS orgs are private enterprises after all. They set the terms, members choose to subscribe. Appraisers always get the surcharge because we’re not Realtors. The governing board of licensed agents is supposed to control the terms. The MLS company itself is not a regulated enterprise and does not answer to the state board.

          The three steps of minimum data verification, which can easily reach into four, five, or more. Assessors data direct. MLS incorporated public records data, our MLS uses Realist public records systems. Data between the two may vary, as Realist may prefer MLS data over assessors, or vice versa, depending on the data in question. Actual MLS data. Historical MLS entries. Physical verification. Depending on the assessors, one may or may not get a sketch, but that’s not always reliable anyways. Systemic data inaccuracies are routine. So we go through all the motions of redundantly qualifying data regardless if we think the data is accurate or not. PDC inspector apps are not going to come anywhere close to this level of data qualification.

          For the trainee argument, disagree. The most valuable training is day to day shadowing for several years of senior appraisers. There should be no substituting that experience. The skills gained are dynamic, multi faceted. Real property, area character, changes in nature of developments, environmental issues, obsolescence, qualifying space. Professional service, questions, dealing with aggressive agency, etc. What in part led to HVCC and DF in the first place was the disassociation with trainees and mentors, which led to many of the systemic industry issues we have today. There is no substitution for the supervised model.

          If we would stop the wholesale pilfering of the appraisers by predatory amc companies, affording time and expense to have apprentices by our side would be a non issue. In turn creating safer and more rewarding working environments for appraisers, and better training.

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          • Avatar Russell says:

            Baggins, I agree with you on the shadowing of a senior appraiser. How many years would that take? As a senior appraiser would you pay them on the engagements you completed and they accompanied you? What percentage does the average trainee get today?

            I do not remember what my percentage of the engagement was because it has been so long ago. I was able to make a good living as a trainee. I did all of the work including the inspections without being shadowed by a senior appraiser. My senior appraiser reviewed all of my reports and would tell me what I needed to do to make the report credible then sign off on them.

            My office was at my home and I never went to the office which was several hours away from me. They had several appraiser throughout the southeast. All of us on their roster would go to quarterly meetings to address issues and go over any updates.

            Can a trainee make a reasonable living today before they become licensed to get a bigger cut if they decide to say on with the company that trained them?

            When I was a registered appraiser the company I worked with gave me so many engagements that I was able to quickly get all of my qualifying hours within the allotted time. This allowed me to skip licensed appraiser and test for certified appraiser.

            In my opinion, I do not see how a senior appraiser can shadow a trainee on every one of their engagements for several years and they both make a good living unless they have several trainees and several senior appraisers. They would have to get a ton of business to make the numbers work.

            The reason I asked these question is because my son in law asked me about becoming an appraiser. I talked him out of it because I did not see how he could make a reasonable living in todays market as a trainee for a long period of time before he could go out on his own..

            I would not take on a trainee unless my income would increase or not go down because of taking on a trainee.

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            • Baggins Baggins says:

              For many years, senior appraisers assisting trainees to get licenses and just signing off on reports after corrections were in violation of many rules, specifically not accompanying the trainee to the inspection themselves. That provided a substantial amount of systemic training deficiency which continues to this day. The requirement for the licensed appraiser to be there in person is a good rule that should not be rescinded.

              A trainee earning a decent living? No. That happens after licensing. Do colleges make a big deal about assuring they’re paying students, or do students pay the educator and take loans to get there?

              How many years would it take? Depends on the experience of the trainee. For well experienced people whom have already been in the workforce and performed complex tasks, far less than younger people. Talk to PSI about that, last I heard they still don’t ask a single qualification question about regulatory guidelines, rather only focusing on appraisal theory. Why there is such a high rate of license rescission is people can literally become licensed and solicit for services, without knowing a damned thing about any of the rules they are subjected to in providing said service. And they don’t learn that by just feeding reports for signature approval to remote bosses.

              Before the appraisal management industry and gse’s jacked up the workflow and redirected so much to realty agents, non appraisers, waivers and such, the senior appraisers provided quality training and had time, because other licensed or administrative staff helped keep up the workflow with pir’s, data entry, communications, basics, etc. Taking a trainee was beneficial and some time off from the grind in a way, partial duty. Trainee holds the dumb end of the tape, drives comps photos, but senior was there to manage the consumer and answer any important questions, assure quality reporting results. Who gives a hoot about consumers anymore anyways, they’ll be fine if the remote trainee process has deficiencies.

              The senior appraiser does not shadow the trainee. The trainee shadows the senior appraiser. You have that backwards.

              I offered PAREA before that was a thing. I’ll still to this day offer to put an appraisers license into anyone’s hand, legitimately, with the full accompaniment of knowledge and skills required, for $10k a year cost. The trainee pays me. I’ll make money. They’ll earn to the license. Their incentive to stay is I’ll buy them into insurance software and everything, if they keep up with me for another two years. Four years roughly, that’s what it takes. Depending on the state, non compete clauses signed pre training may be applicable. The value to the trainee whom will be handed his ticket on a silver platter, is a long term professional connection they can rely on, helping them navigate an overly complex excessive risk and liability system. We’re not making widgets and we’re not supposed to be kicking out new people left and right just to fill chairs.

              Educational providers are not going to provide an adequate substitute for in the field training. And they’d charge far more, only to leave the newly licensed people high and dry with no real world experience or reliable support network. They’ll go down on the first order or contact with aggressive agency, predatory lender, complex challenge, etc, etc.

              There was never any barriers to diversity in this industry, except for the federal governments mismanagement of the GSE systems and failure to enforce C&R rules and the $10k/$20k daily recurrent amc fines for every single order sent out in the past fifteen something years since hvcc. There would have been plenty of trainees and 200k+ appraisers instead of only a fraction of a fraction of a fraction being willing to work with corrupt amc industry modeling today.

              Call someone with assignment portal systems access. Appraisers would be surprised to find how few out of the total volume of appraisers are even still on these systems. They all left GSE servicing because the amc’s are so god damned awful and unfair to work with.

              Get rid of the amc’s and the appraisal industry returns without a second thought. Barriers to entry become a non issue. That’s not going to happen because predatory agency drives policy these days.

              Apply for the TAF position. $500k a year income. All you have to do is sell everyone with a license out.

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              • Avatar Russell says:

                Thanks, great feedback.

                When I first came into the business it was not a requirement for a senior appraiser to accompany a trainee. The state or client required it. Mine did not. The senior appraiser checked they did or did not inspect ect. Yes, some senior lied about it and when the stuff hit the fan they paid for it.

                I know what you mean about shadowing it was a writers slip.

                People coming out of college spending all those years getting an education and paid all of that money for college today will not consider becoming an appraiser today.

                There are too many other careers that they can start out making a good living from the beginning.

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  17. Avatar Dave says:

    Heads up gang -you don’t want to work with these people. What a read!

    https://www.trustpilot.com/review/usbank.com

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  18. Avatar Howard Wettreich says:

    Speaking of ANSI…wanna a laugh? Most of the Assessor’s Office I frequent never even hear of ANSI. So, if you’re using the ANSI method for measuring, do you know what method the Assessor is using for above grade living area? Is it “apples to apples?” What if you’re subject is a colonial and you have to use a cape as a comparable, by using the ANSI method might you be skewing the adjustments for sf and ultimately the final opinion of value? Just asking.

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    • Avatar Russell Bean says:

      True they use a different standard.
      In my area. They have a different standards on counting what is living space especially when it comes to basements. They use a percentage factor depending on the quality of the construction. My State provides the tax assessor manuals and rules on how properties are done on mass appraisals.

      I sat down with the Chief Appraiser and he showed me how to understand the property record card and how they arrived at the data on the card.

      Style should not make any difference in gla and adjusted accordingly based on difference in gla. Adjustments for style differences may be made depending on what the market dictates.

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  19. Avatar Dave says:

    Howard – that can only be true if you believe the market behaves and/or recognizes GLA to the 1/10th of an inch. This is a Lyle Rieke FANNIE thing.

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  20. Avatar Howard Wettreich says:

    Dave, if your subject is a cape and you use a cape as a comparable when you measure the 2nd floor you lose a lot of GLA if the town doesn’t use ANSI as a measuring method for capes when you can only consider 7-foot ceilings as GLA…is what I mean.

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  21. Avatar Dave says:

    Howard – I don’t mean to be picky, but value is not calculated by the sf! and we all do our best to get as accurate a functional use as we can based on experience and judgment, but I must stress the exact measurement to ANSI 1/10 of an inch particularly with knee walls is a bit ridiculous. We should try not to go down that rabbit hole. This like many USPAP guidance will go by the wayside. Bracket your subject with the best comps considering all attributes and then explain why you think adjustment(s) are appropriate. No biggie Lyle Rieke!

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  22. Avatar Howard Wettreich says:

    Dave, I really don’t want to get argumentative. SQUARE FOOT analysis DOES help an appraiser to reach a value opinion. You should know that unless you don’t make sf adjustments. It is part of the adjustment grid. It may be the only area on the grid that’s constantly adjusted. After the adjustment grid is completed with adjustments made or not made, the final values at the bottom of the page are reconciled to help the appraiser reach that final opinion of value. Do you agree? To me, if not to you, square foot analysis is a very important part of value calculation and conducting an analysis helps in that effort. Unlike many appraisers, who do not conduct an analysis, I know this because I also do appraisal reviews, I do. What do I mean when I refer to an analysis of sf when it comes to square feet of above grade living are? Many appraisers just pick a number such as $30 per sf or $40 per sf because that’s what they think (experience and judgement). That is very wrong. USPAP constantly refers to analysis that must be conducted and choosing a number out of the clear blue sky when it comes to dollars per sf, is NOT an analysis. That’s why adjusting for the differences in square feet between the subject and comparables is very important and if done incorrectly, it can skew the final opinion of value immensely which can be interpreted as a misleading appraisal report and a violation of USPAP. So, to an important degree sf helps in the calculation of value. As far as experience and judgement, we all have that, but it goes nowhere when being sued in court or when in front of an appraisal board. I rest my case.

    Show original message

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  23. Avatar Dave says:

    Oh Howard, so much time in what NOT to do, but little or no discussion as to your USPAP compliant statistical correlation analysis appropriate to substantiate adjustments made by YOU!
    I always make that adjustment LAST to see if it is indeed helpful in narrowing the adjusted range. You are correct most boilerplate does include an arbitrary /sf adjustment which often drives the bracket apart instead of narrowing it. Oh Well – good discussion!

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  24. Avatar Dave says:

    Hey Todd, all I am saying is know the difference between primary and secondary data. The latter is often hearsay, opinion and unsubstantiated. I’d hate to see that skew your primary data sending you down the road to – “Well, that is my professional opinion based on 37 years of experience!”

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    • Avatar Todd Redington says:

      Dave, Just so we are on the same page. What do YOU consider primary data vs secondary data?

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  25. Avatar Dave says:

    Todd – look it up -Economics 101!

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    • Avatar Todd Redington says:

      I prefer appraisal 101 and you are deflecting.

      You have made a significant point about differentiating primary and secondary data. I think it is important for those reading your comments to have a clear understanding/definition of what primary and secondary are so as to have the proper context of your comments.

      I don’t think it is an unreasonable, or particularly difficult request.

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  26. Avatar JohnnyQ says:

    The industry’s do gooders and subscribers to DEI clamor for more diversity (not that anyone was or is erecting hurdles for any race or ethnicity of people to enter the RE Appraisal field. They also want faster turn times ( even though who hasn’t seen a revision or addenda to a report be requested 2, 3, a month after having rendered the report). On the basis of all this they’ve created PAREA and now a nee endeavor, that of the PDC while, simultaneously, seeing the ranks of appraisers dwindle and sidelining the appraisal trainee, as many institutions don’t allow and accept work done by the same. This is all unnecessary and self-defeating. Who better to collect the property data than a trainee, allowing the individual to both gain field experience and knowledge, as they progress towards certification and adding new blood to the profession?

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    • Baggins Baggins says:

      If they’d stop sidelining the entire appraisal community, senior appraisers and all, in favor of the amc industry, trainees would be back in the mix. Nobody is sidelining trainees. Because the amc industry did all the hiring instead! The amc industry and their deceptive predatory billing structures has raked billions of dollars which would have otherwise gone to appraisers, and been returned to consumers as cost savings for the service. The solution when conspirators racketeer and collude to defraud consumers and vendors alike, is not to rescind rules that work. The solution is to stop the predatory companies from destroying everyone elses fair dealings and business opportunities.

      This is not rocket science. A. Trainees should always operate under a licensed individual. B. Appraisal management companies are the reason appraisers can not afford to hire trainees. C. Trainees whom came up without legitimate mentors are highly likely to do more harm than good.

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      • Avatar JohnnyQ says:

        Sorry, while AMC’s are part of the problem, remember who they work for. It’s not only AMC’s because I have dealt directly with lenders who do not want any trainee involvement specifically.

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        • Baggins Baggins says:

          Yes. Because the lender is putting the consumers well being first. That’s a great lender and a smart decision, not not allow an unlicensed trainee to pretend to be a legitimate appraiser and run the inspection by themselves without a licensed supervisor present.

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          • Avatar JohnnyQ says:

            Surely. No one said anything about a trainee running solo and unsupervised at the outset of his/her training. The main point, however, is that it makes more sense, in more ways than one, to have the Appraiser trainee do the work of an unlicensed property data collector. A trainee is licensed as you well know.

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            • Baggins Baggins says:

              Troll on. How times change. Supervisor trainee flash cards.

              https://quizlet.com/450347455/supervisorytrainee-course-flash-cards/

              What should a Trainee Appraiser NOT expect from a Supervisory Appraiser?

              paid benefits while in the training position

              The AQB requires the Supervisory Appraiser to inspect properties with the Trainee Appraiser until the Trainee Appraiser is competent to make solo inspections. However, the credentialing authority requires the Supervisory Appraiser to inspect all properties with the Trainee Appraiser. What is true about these requirements?

              Credentialing authority requirements exceed AQB requirements and must be followed.

              Trainee Appraisers are responsible for all of the following except

              deciding when they are competent to inspect properties on their own.

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  27. I work in rural counties of southeast Ohio and West Virgina. I have a hard enough time describing some issues I run in to in a typical days work. I can’t imagine relying on someone else to view a property and collect the data. I have 34 years experience and am still learning something new all the time. I will not complete an Appraisal based on data from an untrained and unlicensed data collector. Agents I know say they are not going to let an unlicensed person enter a listing. I don’t know who came up with the idea of a data collector, they obviously have no idea of the expertise needed to complete an Appraisal. Anytime you stick an extra person in a job it will not speed up the process!

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  28. Avatar kenneth welcher says:

    Simply put the answer to that question should be, yes, a PDC should be licensed… they’re entering homes just like an appraiser and as such should be subject to the same scrutiny and regulations…

    The more nuanced question is… why do/should PDCs even exist?

    Seems to me that it’s not about any efficiencies, but more about divide, (conquer) and obfuscate…as if somehow the forces that be (lenders & amcs) can make the process even murkier and allow them additional opportunities to work the system and skim additional profits.

    In the end, nothing moves any faster or cheaper but in fact probably slower as a result of additional steps in the process and more expensive with more hands in the pot (although in all likelihood, less money for both the appraiser and/or pdc)… and all of it remains hidden from the borrowers (in most cases)!

    I for one am not interested in signing my name (or license) to any job where any work is completed by someone that I personally do not take responsibility for!

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  29. HUD FHA 4000.1 Condition requiring Inspection by a Qualified Individual or Entity, p. 836. This allows Appraisers to refer to an Inspector for required information about the property’s condition. MS HB1663 is not necessary when there is a licensing body already providing the same information.

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Should Property Data Collectors Be Licensed?

by Peter Christensen time to read: 2 min
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