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DODD-FRANK PROMOTES DISCRIMINATION

Dodd-Frank Bill HR 1473 Promotes Discrimination

In April 1992, the Board of Governors of the Federal Reserve System passed SR92-13 which specifically states that “Financial institutions may not exclude a qualified appraiser from consideration for an appraisal assignment solely because the appraiser lacks membership in a particular appraisal organization or does not hold a particular designation from appraisal association, organization, or society”.

This law was passed subsequent to the Federal Government requiring State Licensing and Certifications to combat the public’s perception that appraisers where not educated enough and lacked supervision from the government.

Although both the Federal and State Governments passed these laws, discrimination continued within the appraisal field. Federal and State Governments and their subsidiaries such as the Department of Environmental Protection, Water Management Districts, Internal Revenue Service, Department of Transportation and Banks gave appraisers with designations extra points on their applications to do business with them. Review appraisers, who most likely were designated members of the Appraisal Institute, would in turn give preferential job opportunities to their members (MAI’s).

Appraisers who were not designated consistently complained to these government entities and placed pressure on these groups to stop the blatant discrimination. Numerous calls to the FDIC describing this discrimination often were fluffed off by the attorneys who represented them. In cases, they would sometimes send an email to the banks quoting the discrimination, in turn, the appraiser wanting to perform the appraisals where often eliminated from the Banks appraisal lists.

The new Dodd-Frank Bill, was recently passed in July 2010, page 823 states “CONSIDERATION OF PROFESSIONAL APPRAISAL DESIGNATIONS.—
Section 1122(d) of the Financial Institutions Reform, Recovery, and Enforcement Act of 1989 (12 U.S.C. 3351(d)) is amended by striking ‘‘shall not exclude’’ and all that follows through the end of the subsection and inserting the following: ‘‘may include education achieved, experience, sample appraisals, and references from prior clients. Membership in a nationally recognized professional appraisal organization may be a criteria considered, though lack of membership therein shall not be the sole bar against consideration for an assignment under these criteria.’’.

So there are some questions that remain unanswered.
1) Why was it discriminatory for over a decade and now it’s not?
2) If there are important items that the government requires for appraisers to perform assignments, such as additional education, experience etc., that are offered by the organizations, then why aren’t these factors part of the licensing of the appraisal profession?
3) How can government agencies and banks regulate the appraisal requirements, when the government does not have oversight of these independent appraisal organizations?

There are thousands of independent appraisers, who were once designated members, who believe this is a blatant display of discrimination. They have all worked hard, obtained college degrees, satisfied the required appraisal classroom hours, passed their work experience and a State Certified test. The government/lending institutions are adding additional points for designations even though for over a decade this was a form of discrimination and punishable by law. The Dodd-Frank Law should be repelled to represent the proper appraisal qualifications but to exclude any mention of designations in the bill, unless the government is willing to oversee these private organizations.

Michael Vincent John Spaziani
Michael Vincent John Spaziani, BS, MABA, AMD, MSA
State-Certified General Real Estate Appraiser RZ1167
State Licensed Real Estate Broker
Harvard University, AMD, Advanced Management Development Real Estate
University of Florida, MABA, Real Estate and Urban Analysis

I know this article is beyond the scope of your article but was wondering how you can help the many thousands of appraisers from this blantant act of discrimination.

I think the consumer financial protection bureau is a great advocacy program to help protect consumers from predators. Anytime you confront the TRUTH and expose predators, whether they are "street criminals" or "white collar criminals" who prey off of innocent consumers you are going to be ostracized. And of course the upper echelon won't attack you personally but attack your program’s infrastructure.

I recently was scammed by a former military FISCAL OFFICER who has a top secret clearance background. He had in his possession 50 military "dog tags" which have social security numbers on them. After being investigated he told Naval Criminal Investigative Services (NCIS) while acting as a recruiter the marines gave him their dog tags as a souvenir. This man is still walking around after defrauding our government and marrying 8 or 9 women and stealing their identities by marriage. Should we have a consumer financial protection bureau?.... somone has to protect innoncent citizens!

Dr. Jade K. Brightly, Ph.D.
Consumer Advocate, Author of financial books
www.JadeKBrightly.com
www.CreateSpace.com/3581119

Thank you so much for the great article. I really learned a lot here. Will this affect the banks in any significant way? If I were trying to reduce the mortgage rates in PA , would I be negatively affected through the banks? Thanks!