, 0

Resolved:  To protect the overall public trust.

The ostensible purpose of government is to serve the public good.  Government regulators are charged with quite a responsibility.  A difficult job.  Politics, pulls, jabs, and pokes abound.  Everyone has a different view.

But is that a real goal for 2022? Or a fake goal?

A real goal will line up with the values it speaks to.  It is true to its stated intent.

A fake goal hides its real intention. It sells what is sell-able, in the guise of a real goal.  (Beware of fake goals.  Remember that the first statement we hear, whether a truth or a lie, sets itself first in the brain.  We are programmed that way.)

Is the USPAP stated purpose of promoting “…a high level of public trust” a real goal?  Is it true to its stated intent?  Most public policy starts out this way.  It has to.  The writer wants to look good.  The approving ‘committee’ wants to look dedicated.  “Stakeholders” smile.

Similarly, FFIEC (Federal Financial Institutions Examinations Council), comprises several agencies and is charged to ”prescribe uniform principles, standards, and report forms for the federal examination of financial institutions.”  Title XI of the Financial Institutions Reform, Recovery and Enforcement Act of 1989 (FIRREA) also established The Appraisal Subcommittee (ASC) within the Examination Council.

The mission (the stated goal) of the ASC is to provide oversight of appraisers and management companies, as well as monitoring the non-profit, subsidized Appraisal Foundation – “to protect federal financial and public policy interests … in federally related transactions.”

Each stakeholder believes their position serves the public good.  Yet each position is different.

This then becomes the real issue:  What is the real public trust?  And how do we deal with each of the various ‘stakeholder’ interests?  Which faction takes priority?

Each faction may be unaware of their own conflicting intentions.  Humans and their tribes have subconscious thoughts like:  “How will following these proposed rules affect me?  Will it threaten my status?  My dream?  My very safety?  What might become of me?  Why, the very thing I do is for the public good!  How can I possibly be wrong in my wonderful intentions and hard work?”

We create many ‘truths.’  Each stakeholder has a different stake.  A different truth.  A different path to the real goal.  We just have to tweak the real goal without changing the sellable words.

But wait, there’s more!  Each person sees the same words, yet internally sees different things.  Different feelings.  Different assumptions.  Different visions of what others should do.  Others.  If only they would see things my way, my words, my thoughts, the real goal made alive!

Them others.  Seems like they have fake goals.  They just are not able to see the truth.  My truth.  Our truth.  Common sense.  What to do?

I can get angry.  Call them names.  Call them out for their stupidity and mistaken beliefs!

And I will feel better about myself.  I will quickly set myself out to show how smart I am, just by noting how stupid they are!  Easy.  No real evidence needed.  Just strong insults and dismissal.  I feel good.

Now I will seek out others who believe as I do.  Surely some of them have actually done the research.  They have strong beliefs.  And there are many of them.  Us.  We.  We are right!  It must be.

Public trust:  to serve it is difficult at best.  The public has no direct voice.  Stakeholders are loud and present.  Expediency.  Practicality.  Doable-ness take precedence.  Then we have unintended  consequences and forgotten real goals.

A fake goal misses the mark because:

  • You focus is off of the real good;
  • It makes you look good, not be good;
  • Takes less effort, and you still get paid;
  • Helps others with their particular fake goals;
  • Puts ‘real goal’ proponents on the defensive;
  • Helps put the other ‘fake-goalers’ on your side.

The current challenge of FFIEC is difficult.  Real goals require great truths.  The current bloated system did not work.  To make it work will require simplification and recognition of basic realities.

This is about national economy interests not state geographical in nature.  It is about risk, not more layers of regulation.  It is about being good, not looking good.

The coming three weeks, we continue the series on “Is Appraisal Obsolete?”