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-- TEXAS -- One State’s View AQB and ASC Developments after Dodd-Frank Douglas E. Oldmixon

-- TEXAS -- One State’s View AQB and ASC Developments after Dodd-Frank Douglas E. Oldmixon TALCB Commissioner & Former Board Member. RECIPROCITY Is applicant in good standing on registry? Is home state in good standing with ASC? Are home state standards > Texas? Areas of concern =

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-- TEXAS -- One State’s View AQB and ASC Developments after Dodd-Frank Douglas E. Oldmixon

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  1. -- TEXAS -- One State’s View AQB and ASC Developments after Dodd-Frank Douglas E. Oldmixon TALCB Commissioner & Former Board Member

  2. RECIPROCITY • Is applicant in good standing on registry? • Is home state in good standing with ASC? • Are home state standards >Texas? • Areas of concern = • - only new requests for credential – really? • - criminal history check – national agency check? • Delayed to 2017 – costs? platform? NMLS? • - state law content – state law differences?

  3. REVIEWS Reviewer must be certified by some state at same level required to have completed report - BUT in this state? - If lives in, works in or comes into TX - yes - If reviewer is developing a value opinion - yes - But if OOS reviewer is only opining on quality of appraiser’s methodology, then why critical? - In TX – current law requires a TX cert if review is for AMC to comply with 1 of 5 & 5% yrreq(2%)

  4. SUPERVISOR / TRAINEE - Required course for all new sponsorships (one time) - One trainee may have more than one supervisor - What about existing? Burden? Keeping track? - Supervising Appraiser may not sponsor more than 3 trainees at one time, unless state provides training and monitoring program - Working on plan for non-disciplinary assistance audits

  5. ENFORCEMENT • - Get really bad ones out of the profession • - Correct errors in methods and techniques by appropriate education or training • timely complaint intake processing • - not a “complaint” on your record • contingent dismissals for minor mistakes • - effective mentoring program • probated suspension for major issues • use only appraisers to investigate / PICs • anonymous complaints are poisonous

  6. AMC Related Issues • - Final fed rules coming; “interim” final now • AMC Registry Fees are coming ($25 ea?) • – no pass-through fees in TX ($700K) • Delayed or Unaddressed issues – • - Reports are USPAP complaint? reviews • - Paying C&R fees? presumptions • - Appraiser Independence – anonymous? • - State audit AMC reqs? guidelines • - Other Concerns • - background checks – multiple non-CH • - mandatory reporting – if material impact

  7. Q&A Texas Appraiser Licensing & Certification Board (TALCB) Douglas E. Oldmixon, Commissioner 512-936-3001 commissioner@talcb.texas.gov

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