An Appraisal Management Company has one purpose, to be an unbiased third-party middleman between the lender and the appraiser. Their sole purpose is to eliminate undue pressure on the appraiser; to insure appraiser independence. This is mandated in both Federal and State Statutes throughout the country. When you provide pressure, threaten a complaint to the State Board, change weighting calculations and email them to the appraiser all with the purpose of a different value, you fail at your purpose.
On Monday March 16, 2026, the Virginia Real Estate Appraiser Board suspended the licenses of Financial Asset Services, Inc (FAS) and their Chief Review Appraiser, Brandon Sison. The evidence in the case was strong and well documented. Emails threatening to turn the appraiser into the state, withholding payment, reweighting the comparable sales for a different value and emailing those calculations to the appraiser. For two years Virginia will be watching Financial Asset Services and Brandon Sison. They each have a 6-month suspension of licensure and an 18-month probationary period following the suspension.
We all know each state has different laws and when it comes to appraisers and AMC’s, most states follow the federal laws. Virginia also requires each licensee to report all disciplinary action against a licensee in other jurisdictions to be reported to Virginia within 30 days. Failure to report the disciplinary action is a violation of the regulations and grounds for disciplinary action. Some other states require this as well. Due to the seriousness of the violations, will other states open their own investigations?
Regardless, this disciplinary action and the case files are publicly available on the Virginia Department of Professional Occupation Regulations’ website. Additionally, the Appraisal Subcommittee reports disciplinary action to the public as well. One thing is certain, the GSE’s and lenders will be watching closely.
Appraisers should not be afraid of referring AMC’s and review appraiser to the State Boards. The only way to stop the illegal actions are to stop the people committing them.
Once again the Commonwealth of Virginia shines the beacon of justice by leading all states and and AMCs in the correct direction.
All lenders beware of what you may be exposed to in selecting or even using such agents as your representatives!
Well done VaCap, DPOR,and AARC
Great work and crucially important – thank you!
Thank you
The case gets dismissed.
Where does the penalty from the AMC come from? I read the entire report.
I am confused the AMC is found to do nothing wrong (and having been a reviewer for almost 40 years now, I 100% agree with the Board on that….the reviewer never influenced or cared about value….simply asked for support which apparently never was given. seems like not supporting adjustments is the USPAP violation in this example).
But, all of that aside, I must have not been provided with some other case or document where the AMC was found to be at fault on something they did. Anyone that has that please provide. Just curious what that is since the main part of the case they were found not guilty of anything and it was dismissed.
Not sure what you are referring, but the case was never dismissed. The Board makes a determination as to the merits of the case based on all the evidence. The issue is not about the appraisal report, the issue is about the actions of the AMC and their employees. It is a illegal at both a state and Federal level to interfere with the independence of an appraiser. Specific examples were pointed out to the AMC by the state investigator during the investigation process, prior to the Board even seeing the file. From what was witnessed by someone present at the meeting, the Board vote was unanimous on the pressure placed on the appraiser.
As I fully expect, no one will admit to the FACT that the appraiser did not provide support for his adjustments. My 40 years of reviewing has only found 1 (!!!) appraiser to ever support the GLA adjustment for residential appraisals (funny part was it was a commercial appraiser doing an eminent domain project with many houses affected). Never seen any support for the made-up physical and locational adjustments in any residential appraisal ever. Likely the same occurred here. As an aside, I have seen some support for Market Conditions Adjustments over the decades.
In everything available to the public re this case, the reviewer never ever insinuates a value. But, that is secondary to the appraiser never ever meeting USPAP as requested by the client. Again, no one on here will admit to that issue and the appraiser being in the wrong (based on not seeing any detailed adjustments analyses in the public record….). The good part at least the ‘what your peers do’ argument in USPAP sides with the appraiser as all residential appraisers throw out unsupported adjustments in every appraisal and never confirm the comparables sales with parties to the transaction (I had one appraiser taking pics of the house I bought in Virginia and we explained why it was a distressed sale….he said I don’t care and I am using the sale price and drove off!!!). No other appraiser has ever called us to verify our purchases.
Really tough for me to find ANY client at fault when an appraiser does not provide anywhere near sufficient support for the adjustments, doesn’t reconcile to the lowest gross adjustments sales (I am NOT saying this happened here as I have not seen the appraisal in public records, yet….being general on these comments not specific to this situation), et al. A client has every right to get a fully supported appraisal.
Although this situation did not fall under FIRREA, the following verbiage likely appears in other government agencies policies:
An institution should file a complaint with the appropriate state appraiser regulatory
officials when it suspects that a state certified or licensed appraiser failed to comply with
USPAP, applicable state laws, or engaged in other unethical or unprofessional conduct. In addition,
effective April 1, 2011, an institution must file a complaint with the appropriate state appraiser
certifying and licensing agency under certain circumstances.³⁷
——
So, a reviewer doesn’t need to say it out loud about turning the report into the State. But, it sure doesn’t hurt to state such if that is what they are required to do. Far from a threat or coercion to simply state the action that is required of them. If a police officer tells me to do this else I will be under arrest, that is not a threat or coercion. I consider it to be a promise:) You don’t want to meet USPAP and Engagement Letter and Client requirements, it’s a promise what is going to happen to that report:) And, yes, an appraiser has every right to tell the reviewer I think this is coercion and I am turning you into the state. Go for it I say….I will take a coercion allegation against an unsupported not-in-compliance with USPAP and state law case challenge any day. It’s only life, let’s put our work up for legal scrutiny every day:)
And what is NEVER mentioned in any of the above???? a targeted value. As the reviewer is on the record saying (I think he stole my words!) – I don’t ever care what the value is. I just need a supported value. Til this day, he probably hasn’t got that, yet:(
Vent away….no, I no longer own an AMC (never dealt with residential outside FIRREA when I did) and am not caring what happens to FAS or any of them. no vested interest either way. just watching March Madness and enjoying my semi-retirement. BTW, hope you are doing well PAT….enjoy retirement while you can my friend!
You are not seeing all the back work behind this
Call me if you need to
Hope you are well!!!
Way to go, Virginia! FAS is awful.
I guess this wasn’t the final ruling, but it was based on the most detailed information per what is made available to the public:
Further, Alvarez credibly explained FAS, lnc.’s process regarding timely payment when a complaint
needs to be resolved regarding potential USPAP violations. The documentation in this case shows
that FAS, Inc. informed Leonard that payment for the appraisal had been “put on pause” pending
referral to the Department. Once the Department resolved the case in Leonard’s favor, he received
payment. I find that FAS, Inc. did not threaten to withhold payment in order to influence the
outcome of the appraisal, but simply informed Leonard of its procedures when a case is referred to
a regulatory agency.
Therefore, I recommend that the Board close Count 1 of this file with a finding of no violation of
Board Regulation 18 VAC 130-30-160.9.
By:
Mark ChatJ/11r-FA
Mark Chapin IFA (Jan 9, iJ2614:13:59 EST)
Mark Chapin
Presiding Board Member
REAL ESTATE APPRAISER BOARD
14
Jan 9, 2026
Date: