Attached you will find a set of "Findings" adopted by the State of Illinois Appraisal Licensing Board.
Our board, like many others, does not have the authority to write rules. The board does, however, have the authority to interpret USPAP and state law in the recommendation of disciplinary actions.
In issuing "findings" we are informing the appraisers in Illinois of what the board would likely find, if an individual were to be investigated for any of these specific issues.
Finding 1 - Deals with the issue of who is the client - an AMC or a lender. This issue was raised because many AMC's do not wish to be disclosed in an appraisal report. This finding is based upon our interpretation of USPAP.
Finding 2 - This finding deals with "agency." It has become an issue because the Federal Interagency Guidelines do not deal with the issue - leaving it to us. This finding is based upon our interpretation of USPAP.
Finding 3 - Disclosure of appraisal fees. This finding is based upon our interpretation of USPAP. We also find this need for disclosure to be a transparency issue and being in the public interest to disclose the actual fee.
Finding 4 - We have found many companies use "out of state" appraisers to "review" appraisals produced by certified Illinois appraisers. Couched in these "reviews" are often conclusions of value. This finding is based upon our interpretation of Illinois law.
Finding 5 - This finding is meant to deal with the issue of an appraiser being knowledgeable of an AMC altering a true copy of the appraisal report when delivering it to an intended user. This finding is based upon the Board's interpretation of USPAP.
Our goal in distributing these findings is that other state boards might find it useful to adopt similar "findings."
Click here for the complete findings - Download StateofIllinoisFindingsAppraisal
Robert Gorman, Chair
State of Illinois Licensing Board