Illinois - "Comp Check" Complaint Form

Our earlier blog post Can you check comps for me? I want to know if I should order an appraisal included the ICAP instructions asking appraisers to email Value/Comp Check requests from lenders to the Illinois Department of Professional Regulation. 

ICAP has now been informed that Illinois has a special form [(6-2(4) Report] that appraisers must fill out and mail-in with a complaint.

Section 6-2(4) of the Residential Mortgage License Act of 1987 (“Act”) provides for the submission to the Office of Banks and Real Estate (“OBRE”) of an incident report involving an employee of a licensee that has knowingly submitted or caused to be submitted documents that contain willful and material misstatements of facts in connection with any licensable activity as defined in Section 1-3(a) of this Act.

Appraisers can sign the complaint if they want, or can simply write in the word ANONYMOUS on the signature line. The State told ICAP, "the more complaints against a specific lender the better".

Please mail your complaints to: IDFPR, Banking Division, Attn: Elba Aceveda, 122 S. Michigan Avenue, Suite 1900, Chicago, Illinois 60603

Download the 6-2(4) Report "Complaint Form" - click here.

T.J. McCarthy of the Illinois Coalition of Appraisal Professionals (ICAP) says

Completing this form and mailing your complaints in makes us jump throw a few more hoops, but it is still worth it folks. ICAP will ask the State if they will accept a complaint if it is faxed, as long as the special complaint form and supporting documentation is included.

Working together with the State to stop bad professional practices is one of the reasons ICAP was created in the first place. Protect the public trust and protect your profession from this type of industry pressure.

Thank you in advance to all ICAP members willing to take the time out of their busy schedules and file a complaint(s) against any lender requesting Value/Comp checks.

Upon receipt of the complete 6-2(4) Report, including the signature, OBRE shall:

1. Complete an in-office review of the 6-2(4) Report and supporting documentation;
2. Conduct a phone or in-person discussion with company or individual submitting the report;
3. Upon confirmation of the report, OBRE will send a letter to the respondent that the report indicates has violated the law. This letter will set forth the allegations;
4. The respondent will have a reasonable period of time to respond in writing to the incident report;
5. Upon receipt of the response, a meeting will be scheduled with the respondent to discuss theallegations;
6. Within a reasonable period of time following the completion of such meetings, OBRE will decide,
7. based on the merits of the case, whether any of the parities will be recalled or a formal hearing will be conducted; and
8. Once a decision is made and a formal hearing is required, all parties involved will be notified.