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  • Writer's pictureJesse Ledbetter

How to submit a Dodd Frank violation.

Any appraiser who has worked for any length of time has made someone unhappy. Failure to "hit the number," noting a federally required repair that "kills the deal," standing your ground on any number of USPAP/Ethics/Legal issues. The appraiser, at best, is a minor inconvenience to the other parties in the deal (it shouldn't be this way, but too many see it this way) and at worst, the enemy. That doesn't mean that the appraiser is defenseless.

The Appraisal Foundation has said:

"Within USPAP, the concept of the “public” refers foremost to those people who have a relationship with the appraiser, such as the client and any other intended users.

However, the appraiser also has a responsibility to protect the overall public trust.

These public trust relationships are similar to those of an accountant performing an audit of financial statements. The auditor must maintain the trust of both the client (the firm being audited) and of the investing public by competently performing work that is credible and done in an independent, objective manner."

If an appraiser witnesses a crime being committed during the performance of their work, and fails to report it, can they be considered "independent" and protecting the "public trust" if they fail to report that crime?

What crimes are appraiser's uniquely positioned to witness?

Mortgage Fraud (Various state and federal codes)

Attempts to inflate/deflate home values (Dodd Frank)

Racial Bias - on the part of any member (agent, loan officer, another appraiser)(Fair Housing Regulations)

Black listing of appraisers (TILA)

Failure to pay customary and reasonable fees (Dodd Frank)

Retaliation against the appraiser for reporting of crimes (Dodd Frank)

These are all crimes. Period. Some carry jail time, some carry fines, but each is a breach of a federal law. While we are not the judge of these crimes, we have a duty to report these crimes. Luckily, the Dodd Frank Act required that the Securities and Exchange Commission establish a mean by which these crimes can be submitted.

Appraisers, if you see something, say something.

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