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Posts Tagged ‘The Appraisal Foundation’

With All That PPP And Without All That Travel, The Appraisal Foundation Doesn’t Need A Grant From ASC This Year

August 19, 2020 | 1:36 pm | Investigative |

This post previously appeared in the August 14, 2020 edition of Housing Notes. I’ve been writing these weekly summaries on housing topics for more than five years. To subscribe for free, you can sign up here. Then you can look forward to each issue every Friday at 2pm New York Time.

The TAF decline in credibility keeps on coming…

After the recent letter debacle where the Appraisal Foundation (TAF) opined falsely that Title XI did not permit the Appraisal Subcommittee (ASC) to provide oversight on TAF, we now have a letter from TAF essentially saying they are making so much money that they don’t need a grant this year from ASC. Who is writing all these letters? It can’t be Dave.

[click for full pdf]

In other words, because TAF saved so much money from not being able to fly around the country during the pandemic, they don’t need ASC Grant money this year. From this point, it’s only a hop skip and a jump to saying they don’t need the grant money so therefore they don’t need oversight. And grant money comes with “strings attached” – that the money used from a grant had to be accounted for to the ASC. And if TAF doesn’t need oversight this year, what is to stop them from raising USPAP related fees and stop collecting grant money forever? The conspiracy theorist in me is starting to worry about that aspect of this new more forceful tone out of TAF these days against any oversight.

No Grants = TAF + PPP

Why would the TAF turn down the annual grant process but still have the need to request PPP? What is the hardship they are declaring when they are saving hundreds of thousands in travel costs that are already questionable in their scale?

My appraisal firm in Manhattan applied for PPP because our business collapsed more than 90% almost immediately for two months. It enabled us to survive. I would think it would be obvious to TAF that their $626,000 annual travel expense would collapse. What other revenues would be sharply curtailed in the new online world?

That’s why Jeremy Bagott, MAI, AI-GRS, the Cosmic Cobra guy, issued this press release on July 6th:


* * * FOR IMMEDIATE RELEASE * * *


WITH MILLIONS IN CASH AND STOCKS, APPRAISAL FOUNDATION HAULS IN CARES ACT RELIEF

(LOS ANGELES, July 6, 2020) – Over the years, the tiny, publicly funded Appraisal Foundation has built up a large reserve in cash and publicly traded equities. Its war chest grew from $3.6 million in 2010 to $6.5 million in 2018, the most recent year its IRS Form 990 is available. Its Cause IQ peer nonprofits had nothing like it in their reserves. Despite this burgeoning pot, it has continued to receive public grant money each year from state-licensed appraisers via the mandatory National Registry Fee. In early July 2020, it was learned that, despite wielding this hefty reserve and its guarantee of annual public grant money, the nonprofit also applied for and received CARES Act relief through the Small Business Administration of between $150,000 and $350,000. This is money that could otherwise have gone to struggling mom-and-pop appraisers hurt by the pandemic.

From 2010 to 2018, the nation’s licensed appraisers paid the 14-employee organization more than $6 million through the mandatory National Registry Fee. The group then parlayed that subsidy into more than $27.6 million in publishing revenue extracted from the same captive appraisers during that time. It has copyrighted the publicly subsidized materials and granted exclusive online course rights.

In 2017, the foundation paid its top officer more than $760,000 in an internal retirement-plus-salary deal that effectively doubled his pay from the previous year. For 2018, trustees paid him $414,000 – less than the previous year’s haul but still more than twice the salary of the chairman of the Federal Reserve, who oversees 20,000 employees and the nation’s central bank.

These issues would be no one’s business were this organization not receiving guaranteed annual public grants, tax-exempt status and allowed to wield a government-authorized publishing franchise and contracts with the U.S. Department of the Interior and Department of Justice – and it is now receiving PPP money. A congressionally authorized federal contractor with guaranteed public grants is not what lawmakers had in mind when they passed the CARES Act, which includes the PPP program.

During this pandemic, expect to see licensed appraisers further weakened with fewer options and higher license upkeep costs. Expect the nonprofit to further leverage its copyrights – the development of which appraisers pay for. It is now receiving CARES Act relief. It has never let a good crisis go to waste.

If you’re frustrated, here’s something you can do right away:

Email Mark Abbott, Grants Director at the Appraisal Subcommittee, at Mark@asc.gov and James Park, its Executive Director, at Jim@asc.gov and tell them you want the Appraisal Foundation’s next grant to be reduced by whatever public funding the foundation has received from the CARES Act during the pandemic and its reserves of cash and publicly traded securities, which totaled $6.5 million as of its most recent IRS Form 990. The $40 National Registry Fee paid by appraisers each year ($80 at biennial license renewal) needs to be rolled back by a commensurate amount to provide relief to appraisers. The waste and abuse going on at this tiny nonprofit is being underwritten by the public and it needs to stop. Please cc Arthur Lindo at the Federal Reserve at arthur.lindo@frb.gov.


    • *

About “Dispatches from the Cosmic Cobra Breeding Farm”: The culmination of two years of research, a new book illuminates over-the-top spending and questionable dealings at the familiar Beltway nonprofit. Published just before the pandemic, it chronicles international jet-setting by officers and trustees, conflicts of interest, lobbyist tie-ins, outsized cash reserves and swollen pay at the tiny nonprofit. The book is available at Amazon in paperback and Kindle versions. You can read more about it on the book’s Amazon page.

The Appraisal Foundation’s IRS Form 990 may be viewed online at Propublica’s Nonprofit Explorer. To find it, Google “Propublica Nonprofit Explorer” and type “Appraisal Foundation” into the search box and follow the links.


# #


Here is another email from appraiser Jeremy Bagott (The Cosmic Cobra guy). Bold my emphasis.


Dear Colleague,

Thanks to the Small Business Administration’s data release on July 6, a few news outlets are working doggedly to expose organizations that, with dubious need, have applied for and received federal PPP relief. Ryan Tracy of the Wall Street Journal recently wrote about double-dipping by state highway contractors in Florida who applied for and received PPP relief despite holding government contracts unaffected by Covid. You can read the story here (but you’ll have to get past the Journal’s paywall).

A rogues’ gallery of organizations that have applied for PPP relief include Harvard University (with its $39 billion endowment), the Los Angeles Lakers of the National Basketball Association (with its reported $3.7 billion valuation) and, yes, the congressionally authorized Appraisal Foundation. The former two were shamed into giving the money back once the matter was made public.

Unlike Harvard and the L.A. Lakers, survival of the Appraisal Foundation and its paid panels is literally guaranteed in a federal statute. The statute mandates its guaranteed annual government grants. The making of the grants is part of the Appraisal Subcommittee’s charter. According to its IRS Form 990 for 2018, the most recent available, the Appraisal Foundation spent $626,000 on travel that year. (If past years are any measure, some of it was on international junkets for top officers and favored trustees.) It no longer has that travel expenditure due to the pandemic. The foundation also had $6.5 million in cash and publicly traded equities, according to its 2018 tax form. Why did it apply for between $150,000 and $350,000 in PPP relief?

If you now google “Appraisal Foundation” and “PPP,” the top hit is a CNN Politics site that identifies the Appraisal Foundation as a nonprofit that has applied for and received PPP funding. You can see it here. The Wall Street Journal and CNN are doing God’s work in this respect.

If you’re frustrated, here’s something you can do right away:

Email Mark Abbott, Grants Director at the Appraisal Subcommittee, at Mark@asc.gov and James Park, its Executive Director, at Jim@asc.gov and tell them you want the Appraisal Foundation’s next grant to be reduced by whatever public funding the foundation has received from the CARES Act during the pandemic and its reserves of cash and publicly traded securities. The $40 National Registry Fee paid by appraisers each year ($80 at biennial license renewal) needs to be rolled back by a commensurate amount to provide relief to appraisers during the pandemic. The waste and abuse going on at this nonprofit is being underwritten by appraisers (who are also voters and taxpayers). It needs to stop. Please cc Arthur Lindo at the Federal Reserve at arthur.lindo@frb.gov.

Best regards,



Jeremy Bagott, MAI, AI-GRS
jbagott@gmail.com


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Real estate appraisers are an essential business and here to protect the public trust

March 24, 2020 | 8:00 pm | Milestones |

I hope all my readers (and everyone else) are staying safe and healthy during this crisis – now let’s get to business.


With New York State on lockdown, real estate brokers/agents can’t sell real estate right now because they are not considered an essential business (yet they are in nearby Connecticut!) This declaration determines whether you can or cannot remain in business during a crisis like this.

Are real estate appraisers considered an essential business in New York? Yes. They are in New York State and they are stated as such in the federal Gramm-Leach-Bliley Act of 1999. But the fact that real estate appraisers are an “essential business” is not consistent in the federal language, especially now when many states are, or will be going on lockdown.

My good friend and appraiser/regulator Pete Fontana and I wrote a letter nicknamed: Fontana/Miller Essential Letter of March 24, 2020. This letter combines the scattered references to address this issue in very specific terms using key language in the public record that illustrates the fact that appraisers are an “essential business” now and going forward.

This letter is the first to address this important issue. It was just sent to Congress, state officials, trade groups, agencies, and other groups related to our industry today and went viral industrywide. The feedback from these groups has been immediate and overwhelmingly encouraging and positive.

Please share the Fontana/Miller Essential Letter of March 24, 2020 with your colleagues in the industry, trade groups, state governments, on forums, and with anyone or in any place you think is relevant to our industry.

Real estate appraisers are an essential business in our country, always have been.

Stay safe!

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[Appraisal Infographic] Common Myths About The Homebuying Process

March 15, 2014 | 1:07 pm |

The Appraisal Foundation published an appraisal infographic that attempts to clarify common misconceptions by the borrowers about the appraiser’s role in the home buying process. The content is amazingly simplistic, but that’s the point.

I continue to be amazed at how so few people don’t understand what the appraiser’s role is in the home buying process. Perhaps this is why the appraisal industry continues to be marginalized in the lending process (ie appraisal management companies, Appraiser Independence Requirements) and the exodus of competent appraisers into other disciplines outside of residential mortgages continues.

2014-03-06-BorrowersinfographicTAF

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[Vortex] Did We Get There? The Promise of Licensing Appraisers

May 22, 2012 | 11:32 am |

Every so often, a Matrix reader submits something they feel very strongly about it and bravely enter the Vortex where I post it.

Guest Columnist: Cecil Simon

Cecil has been a New York general state certified appraiser since 1992. He takes a look at the intersection of professional education and licensing. He’s weighed in here before. Like me, Cecil was an appraiser before the licensing law in 1989 and in fact wrote Congress about this matter as early as 1986.

Admittedly this is super appraiser wonkiness, but it’s worth the read.

-Jonathan Miller



May 12, 2012

Did we get there? the promise of Licensing Appraisers.

How technically prepared are Certified General Appraisers? A recent editorial by Henry H. Harrison in his Real Estate Valuation Magazine, suggested the answer is not very well. In fact, Mr. Harrison even challenged readers to provide evidence that Certified General Appraisers did not make at least 80% of their living writing residential work.

I believe he is correct on the preparation issue, and incorrect on what Certified General Appraisers do in the industry. Most Certified General Appraisers have now become the workhorses for fee shops run by designated appraisers, working as independent contractors at low rates and without benefits. This was by design, and the education and experience requirements set by the Appraisal Qualifications Board in the early 1990s, later amended in 2008, bears me out.

It is now generally accepted that the requirements for General Certification set in 1991 were deplorable, although Harrison and other in his group did not think so when I first wrote to him in 1993. The 2008 fix with the addition of a course in Highest and Best Use and Market Analysis, and one in Report Writing was a plus, but the remaining content was just a split of two former lower level courses into some 120-140 hours. The final product was three hundred classroom hours, more than were required for the MAI in 1990, yet these were junior courses.

FIRREA had a specific mandate. That mandate required that the education and experience required for General Certification be such, that a person with those qualifications would be able to appraise any property without regard to value in a Federal related transaction. That is a high standard, which was well known to the Chairman and members of the Board from 1991 to 2004, yet they did otherwise. The reasons often given in support of the lower standards were the use of the term minimal education required, that States could add to the basic core, and that Certification requirements were intended as a beginning. But the mandate certainly does not imply that.

Basic appraisal education requires only six courses, seven if you add the new Quantitative Analysis course, which is a plus. The seven courses are Appraisal Principles and Procedures, Highest and Best Use and Market Analysis, Land Valuation and the Cost Approach, Direct Sales Comparison Approach, Income Approach, Quantitative Analysis, and Case Study and Report Writing. These names can be applied to Residential and General [Vortex] Did we get there? the promise of Licensing Appraisers.

Certification courses with different content, and all that is currently listed by the Appraisal Institute as Level 1 and 2 and required for their MAI designation can be covered in those seven courses. Hours can be assigned based on the content to be covered.

The seven basic courses plus four years of experience, and the State Exam, is more than adequate to lay the groundwork for Certification as well as any designation. It should be noted that the six courses used prior to 1990 for the MAI, and the four used for the SREA (101, 102, 201, 202), were all taught in less than three hundred hours. These courses produced some of the best educators and practitioners currently working in the industry, including Mr. Harrison. Even Universities that grant Undergraduate and Graduate Degrees in Real Estate offer only one or two courses in Valuation.

I took the trouble to review the education requirements for all of the original members of the Foundation that deal specifically with Real Property interest. The Appraisal Institute of Canada arguably has the best program, and the Appraisal Institute is the only one with Advanced Courses. Some startling facts also come to mind. The education requirements for the MAI designation have increased from 267 hours in 1990 to 482 in 2008, an increase of 215 hours, all without any change in the theory and methodology of valuing real property. The only industry change during that period was the use of software that makes database searches and data analysis easier. In fact, one group, The American Society of Appraisers could not even remember when they last hosted a basic course.

I believe that The Appraisal Institute is the best professional association representing appraisers and the leader in the industry, but its continued creation of advanced courses in order to create the illusion that its members and candidates are better prepared than Certified Appraisers is a farce. The same seven courses could easily serve as the core education requirements for candidates as well as General Certification. Additional requirements for designations can be added. The MAI designation is a highly recognized brand, and could be granted based on work experience and peer review. Downgrading the education requirements for Certification is a dumb idea, and it is clear that The Appraisal Subcommittee fell down on its mandate to monitor and review the practices and activities of the Foundation.

There are a few good textbooks out there on Appraising Real Property, and I place The Appraisal of Real Estate, published by the Appraisal Institute at the top of that heap. Now I would hope that any State that puts its imprimatur on the qualifications of any individual to call that person a Certified General Appraiser, expects that they have covered the content of that text from cover to cover. That was the intent of FIRREA. But it appears that by separating the content into General and Advanced sections, both the Appraisal Institute and the Appraisal Qualifications Board that it has controlled since 1989 seems not to think so. This difference in education is the centerpiece of Harrison’s thesis.

The Qualifications Board should simply set the education requirement as successful completion of a course in the seven areas and forget hours, and if a rigorous State exam is made part of the process, then The Appraisal Institute will be sure to include much of what it now calls advanced content in those seven courses.

On the issue of college education, professional associations may find this a plus, and hopefully the appraiser has written enough college papers to be able to write properly, but degrees in most disciplines will not make you a better market analyst.

The answer to my original question is yes and no. We now have a mechanism to punish bad apples, although better enforcement is needed, but the standards for education, experience and testing did not.

C M. Simon.

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[Interview] David C. Wilkes, Esq. CRE FRICS, Huff Wilkes & Cavallaro LLP, Chairman The Appraisal Foundation

September 15, 2010 | 10:13 am | Podcasts |

Read More

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