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Posted

I'm working with the directors of the real estate department at a couple of local (well known and respected) law schools to develop a set of criteria for new real estate attorneys in evaluating HI's. The director gets it, understands NAR sucker punch tactics, and wants the new attorneys to effect change where it counts. The course material will be online, maybe MOOC at some point. There will be a video showing the basics of a home inspection and an interview where we hit the high points.

This is not a "How To" class; that's not the point. It's how one might evaluate whether one's client is receiving a competent inspection.

So, to that effect, we've developed a couple of angles.

First, I want to delineate the different approaches between new and old property inspection, with focus on water and it's effects on both.

After that......

1) What should a competent home inspection report contain? Format? Length?

2) What should a competent home inspection entail? Obviously State SOP and licensing stuff, but I want to go beyond that to get at the real stuff. I will continue to insist on things like inspectors actually climbing on roofs, or including common elements in condominium inspections. Safety stuff, yes, which goes on forever. What else?

I'll be getting video'd on this, using a couple sample houses in Chicago. I want to shoot some of it on roof, some in a basement. Again, this isn't a how to, but what would be the salient talking points about inspection process?

3) We'll be talking about what "certified" means, and the intricacies of understanding the various HI professional society approaches to the game.

Once online, we'll be going to the local attorney professional association (big and powerful) and presenting to the crowd at a couple of conventions. It could be a big deal game changer.

I, of course, have my own ideas. I want more ideas than my own. Anyone want to put up bullet points for consideration? I greatly appreciate anyone's input.

Posted

1) What should a competent home inspection report contain? Format? Length?

Format. Agents ask for this all the time. They want all home inspection reports from all inspectors to be the same format so the agent always knows where to look for stuff. Understandable from their viewpoint. Buyers only ever see the one report and that is the only one they care about. Whatever format they get is what they have to figure out. Inspectors become very heavily invested in their format and loath to change it for anyone or any reason.

Standardization is not a bad thing but which is better, sorted by systems or sorted by rooms. Should there be an electrical section with all electrical stuff or should electrical be spread out across all the various rooms? Does it really matter as long as all the data is in the report?

Length is inconsequential. If there is a photo for every defect, the report will be much longer than without photos. Requireing a photo for every defect can create quirky issues. Photos of a missing expansion tank make no sense to anyone. How to do you take a photo of rotten egg smell from old water heater?

North Carolina Licensing Board figured out that many of the complaints they recieved eventually were based on poor reporting. They created several mandatory classes on what they thought was proper report writing. They used to be available online but haven't been in a while. You could contact the Exec Director Mike H. and he could probably make the reporting writing classes available. Its just a bunch of powerpoint slides. Bunch meaning 200+ slides per class which was supposed to take 4 hours to present. About 4 or 5 classes.

http://www.ncdoi.com/osfm/Engineering_a ... ub=HILT_CE

NC strongly pushed the DDID format. (Description, Determination, Implication, and Direction).

Description: Describe the component or system and its location

Determination: State how the component or system is defective

Implication: Explain the consequences of the condition

Direction: Direct a course of action or Refer to specialist

Home Inspectors often got hung up on the Direction part. Direction should be something like: Have repaired by a licensed plumbing contractor. HI's should not be documenting a specific repair procedure but rather give the home buyer a direction to start looking for a qualifed specialist. Many people don't have a clue what kind of contractor would need to be contacted to make the repairs they need.

I explained it to my customers as there will be a defect statement saying at this location, this is broken, if you dont fix it you will die, call a specialist.

What about component descriptions? Is the term Plastic Pipe adequate? Or should it be specific like CPVC, PVC, ABS, Polybutylene? The kind of plastic makes a big difference. NC felt descriptions must contain two parts, Type and Material.

What if the SOP has an item to inspect like a Sump Pump. There is no sump pump in the house so nothing is included in the report. The report does not indicate the inspector looked for a sump pump but the house did not have one. The reader could come to the conclusion the inspector did not attempt to check for a sump pump. Medical documentation would require that the report state the sump was checked for but not present. So for every item in the SOP there would be an entry in the report, regardless if it was present or absent. The report would then document the actual inspection process not just what was deemed important by the inspector.

NC accepted photos but did not accept photos in leiu of written defect statements. While a photo may be evident to the author, it may not be patently obvious to a home buyer without words to help guide them to see the default. As is often seen on this and other forums, people post photos and multiple issues are found besides the one intended. Often the intended item is overlooked. I don't believe a Photo Only report should be a valid option.

Contact information for the NC licenseing board

Location:

NC Home Inspector Licensure Board

322 Chapanoke Rd., Suite-115

Raleigh, NC 27603

(919) 662-4480

(919) 662-4459 (fax)

Mailing Address:

NC Home Inspector Licensure Board

1202 Mail Service Center

Raleigh, NC 27699-1202

(919) 662-4480

(919) 662-4459 (fax)

2) What should a competent home inspection entail? Obviously State SOP and licensing stuff, but I want to go beyond that to get at the real stuff. I will continue to insist on things like inspectors actually climbing on roofs, or including common elements in condominium inspections. Safety stuff, yes, which goes on forever. What else?

Well you saw what kind of push back ASHI got when they recently added appliances to the SOP. I think it is a fine idea to raise the bar and set a higher standard, but be careful of what you ask for. Sometimes there unintended consqeuences of requiring what seems like a trival thing.

Recommend you take a look at the Texas SOP. They require things like placing a thermometer in ovens to ensure 350 is really 350 degrees. Appliance inspecting can be as simple as turning on the major functions to test go/nogo or checking to ensure that thermostats are properly calibrated. If you are checking oven temps, are you also checking HVAC thermostat calibration?

AFCI testing. Only on vacant homes? Push the button and reset or do you have to go confirm the circuit is dead with an outlet tester? So you would have to test three times, first to ensure the circuit is working and then a second time to confirm the AFCI tripped and a third time to ensure it reset.

3) We'll be talking about what "certified" means, and the intricacies of understanding the various HI professional society approaches to the game.

Again your probably gonna get some whinners who complain whatever requirements you specifiy for "certification" are too strict or not strict enough.

How many hours of education prior to becoming certified? Can prior work experience be used to apply towards some portion of the required training? Can tests be taken to show significant enough knowledge to skip some training?

What about Code Certification? I personally think all HIs should be required to pass at least the IRC Building portion within the first 2 years. Then be required to pass at least one of the three remaining residential exams every two years until all four have been passed. That is 8 years to pass 4 exams.

The Georgia HI Association requires all members to be Residentail Combo to be a full member. They run a school teaching code classes. They claim they are the only HI association, club, group that requires IRC Combo to be a full member.

What about apprenticeships? NC tried that and abandoned it. Few inspectors wanted to train their competition. They had cases where the mentor lived in a different city and there was no real hands on mentoring. Since they is no real standard, teaching an aprentice is teaching what you know/prefer. Stopping up shower drains to see if pans leak vs. running water briefly to check hot, cold, and basic drainage. People standing in the shower adds weight flexing shower pans that only leak with occupants but doesn't leak when water only. Who decides what is the definitive testing/inspection method?

Posted

I am too. It's an intelligent overview of a lot of stuff. But, it's not what I'm asking for.

I am asking for what folks think should be in a report. Not SOP, and not extemporizing about all the things that one might put in a report, but what folks think is important. Personally, I think appliances are idiotic, but I do them anyway, and they are in the report.

Example:

Report format should be full narrative word processing format w/ an executive summary.

Or...

Report should be a checklist with a 4 point grading system.

Or....

Report should be a summary of defects and safety concerns, and all the SOP inventory stuff should be in the back in a list.

Or....

Report should be room by room and all conditions grouped by room (I hope no one says this).

There's the distinct possibility that no one has an opinion because almost everyone works within one of the major vendors systems. All the report systems out there have totally screwed us up. No one's really thought about it much, or at all. They take what's given them, tweak it a little, and think it's a report. It's a bunch of software developers that have defined how we deliver reports, and HI's being HI's, they've followed the lead and now it's a can of worms. Formats are designed for the inspector to aid their punching items into a PDA and automating report generation, not for reader comprehension.

The NC DDID approach is OK, but what's it really mean within a format?

The other reason I ask is the initial review with a bunch of contributing attorneys are completely confused by home inspection reports. I brought in an example of all the major report systems, and no one understood anything unless it had a summary. No one read anything other than the summary.

So, in my list, summary is the key item. Maybe not for other folks.

If no one really cares, that's fine too. I just thought I'd get a little input.

Posted

1) What should a competent home inspection report contain? Format? Length?

I. Conditions

II. Methods

III. Descriptions &

IV. Findings

The individual findings, for the most part, are formatted like this:

What is it? What does it mean? What to do about it?

Report should be augmented with photos, interspersed with the relevant text.

Any length is fine. Report should be concise, with extraneous material at a minimum. No big white empty spaces. 25 page is plenty enough for any HI report.

Report format should be full narrative word processing format w/ an executive summary.

2) What should a competent home inspection entail? Obviously State SOP and licensing stuff, but I want to go beyond that to get at the real stuff. I will continue to insist on things like inspectors actually climbing on roofs, or including common elements in condominium inspections. Safety stuff, yes, which goes on forever. What else?

I'll be getting video'd on this, using a couple sample houses in Chicago. I want to shoot some of it on roof, some in a basement. Again, this isn't a how to, but what would be the salient talking points about inspection process?

Maybe use the video to demonstrate how the inspector basically just looks at everything, investigates whatevers out of order and perhaps photographs it. Emphasize that checklists should be kept to a minimum or else he will tend to see only what's in the list.

3) We'll be talking about what "certified" means, and the intricacies of understanding the various HI professional society approaches to the game.

They don't mean much, if anything at all.

Once online, we'll be going to the local attorney professional association (big and powerful) and presenting to the crowd at a couple of conventions. It could be a big deal game changer.

I, of course, have my own ideas. I want more ideas than my own. Anyone want to put up bullet points for consideration? I greatly appreciate anyone's input.

  • Nothing gives away the expertise of the inspector like the reports he writes. You'll learn the most about him by reading his works.
  • All home inspection reports describe two things: the house and the inspector. Good ones speak mostly about the house. Lousy ones mostly just illuminate the incompetence of the inspector.
  • Good inspectors are self taught. It's the only way. No one in this country has yet to successfully write and market a curriculum that can properly prepare an individual for a career as a home inspector. So if he's fluent about his subject matter, it's because he learned it on his own.

Marc

Posted

Bruce's thought that one should be IRC competent/certified. What about that?

Should we all be IRC certified? I kinda like that idea, although IRC is meaningless in my work area.

Posted

I spent a fair bit of time working with the NC licensing board on report formatting. Agents wanted a consistent format so every report looked the same regardless of who wrote it or who inspected the home. Part of that was so they knew where to look but mostly because they thought that if the report format was standardized, then all inspectors would find the same problems and report them in the same way. Report formatting doesn't create standardized inspectors or standardized reporting of defects.

Untold time spent in conference rooms arguing over formatting and content. If the summary is at the beginning of the report, then it is not a summary because summaries follow the body. If there is a summary, no one will read the body and the body contains stuff. If no one is reading the other stuff, then why do we need to include it in the report at all? Should summaries contain all defects or only certain defects? Who decides which defects can and cannot be included? How should the summary be sorted? Endless useless talking.

After several years of bickering, it was decided that a Summary was required and only some items could be included while others had to be excluded from the summary. Net result was every report had a summary. Bad inspections by incompetent inspectors still wrote bad reports.

I understand your goal of designing a better mousetrap. In general I agree with your belief that the report is the summary and vice versa. I agree that photos usually tell a better story than words. I agree that home inspectors write reports of their own design or by forcing software packages into their design regardless of what is easiest to comprehend by Buyers.

There is lots of stuff inspectors put in reports because they can. Just because we can doesn't mean we should.

The SOPs tend to drive the most basic report formatting. And then there are the organizationally challenged inspectors who strike out with their own formats. Reviewed reports for several years for HI association and the licensing board. Wow! There are lots of really really bad reports and reporting.

2) you are asking about How to Inspect vs. How to Report. Mandatory roof climbing is how to inspect, not how to report. The multiple HI forums often debate wheather one technique is better or useful at all to perform. Taking air temps inside the supply and return at the HVAC are more reliable than using a laser thermometer at the supply registers. Laser thermometers are measuring the temp of the metal register not supply air. But supply register readings are a good seat of the pants check to see if the system is performing in the ballpark. The second part of the debate is either necessary at all and within the scope of a "visual" home inspection. This goes to the concept of a standardized method to inspect each and every component in a home.

Documenting the right and proper method to inspect each and every component and system within a home. Hope you got lots of time to write that manual. Then try and get a consensus of more than 5 inspectors to agree that the described method is the one and best method. Hah!

Posted

Seasoned lawyers who do alot of RE work should be interviewed as to what they consider a good report to be. The good ones I deal with want a clear summary of problems their clients will have to deal with and pictures.

Lawyers also like written estimates to fix major problems but I stopped doing that years ago because of legal pressure from Realtors and now do verbal estimates only.

"develop a set of criteria for new real estate attorneys in evaluating HI's."

This would be the same, more or less, as what a home buyer should be looking for: Experience, referrals from someone you trust, sample reports, and internet reviews.

Posted
I'm working with the directors of the real estate department at a couple of local (well known and respected) law schools to develop a set of criteria for new real estate attorneys in evaluating HI's. The director gets it, understands NAR sucker punch tactics, and wants the new attorneys to effect change where it counts.

That's it in a nutshell. Start there, and finish there. The rest will eventually take care of itself.

The agents alone, are the single biggest problem with our profession.

Why are a group of sales people who get paid more than we do for simply opening a door, and pointing at the paint, a remote consideration in this conversation?

They come, they go. They don't have the foggiest idea of the knowledge base we're charged with being responsible for, and in most cases, a clue about what we can, can't, should, or shouldn't be doing.

Somebody explain why these people should be holding the reigns on a profession they know nothing about, and means nothing less to them than another obstacle between them and their commission check.

I don't get it. Everyone here is on a level so far beyond that of these half wits, yet for some reason we feel compelled to allow their input to influence our direction? Why?

They're sales people. That's it. Just like at the furniture store. They're not even in our league.

Let's focus on us and separating this profession from those who have damaged it, and turned it into a joke in the eyes of the public.

We can't have it both ways.

Step up, and have the guts to change business as usual. It's harder, but it works.

Posted

1) What should a competent home inspection report contain? Format? Length?

A competent report should contain the information required by the applicable standard of practice - there's no getting around that - and enough additional information for a lay reader to understand the condition of the house.

Every inspector believes that his format is the best and that everyone else's is crap. The reality is that there are many good ways to format information and many more bad ways. The format should be clear and consistent. Aside from that, I'd tell them to expect to see a wide variety of formats. The good ones will be clear, the bad ones will be muddy.

If I were doing the presentation, I'd focus on concepts rather than specifics. For the written report, I'd stress the concept of clarity. Reports should be clear and unequivocal. Readers should be able to choose a page at random, begin reading, and understand what's being said. If a report can do that, then it's a good report.

2) What should a competent home inspection entail? Obviously State SOP and licensing stuff, but I want to go beyond that to get at the real stuff. I will continue to insist on things like inspectors actually climbing on roofs, or including common elements in condominium inspections. Safety stuff, yes, which goes on forever. What else?

As much as you personally may dislike it, the very definition of a "competent" home inspection is one that fulfills the applicable standard. That's it. The "real stuff" as you call it, is something beyond a competent home inspection. I think it's important that you make that distinction.

I'll be getting video'd on this, using a couple sample houses in Chicago. I want to shoot some of it on roof, some in a basement. Again, this isn't a how to, but what would be the salient talking points about inspection process?

My guess is that they're going to need to be told very basic stuff. Like the fact that a home inspection is visual, that we don't take stuff apart, that we can only evaluate what we see at the time of the inspection, that a typical inspection takes X hours. Even though they're educated people, they really aren't going to know this stuff until you tell them. Your tendency is going to be to talk way over their heads - keep it basic, at least at the beginning. After that, you might delineate the difference between a competent inspection and a "top10%" inspection.

Posted

As you know Texas has a very strict report template (format if you like).

Inspectors can do whatever they want within that template (IE: checkboxes, bullets, narrative, JPGs, etc..)

At least the clients are getting a "common template".

Now the verbiage contained within each topic (IE: Foundations, Grading & Drainage, Electrical, Appliances, etc..) is a wild card.

Posted

I support a Manual of Style for HI reports much more than I do a format. Format is an intermediary step to an eventual HI Manual of Style. It's constrictive like a checklist and it's a trap too. We may get stuck in it for decades if we let neighboring professions box us and our reports, making us all look like we came off an assembly line...'they're easy now, just learn one, and you know them all.' My a_ _!

Marc

Posted

This is all extremely helpful. Extremely.

At base, I was just looking for almost a quick polling type response, and I got a lot more here. I'm actually not trying to build a better mousetrap in this project. I'm trying to get a sense of what a cross section of good inspectors think and how to convey that to the attorneys.

I agree with the NC realtors on some their complaints. Lots of the packages are bad to begin with and a made worse by goofy inspectors without a clue re written communication. It's only reasonable to ask for a report one can understand. Expecting total civilians with zero background in any of this stuff to understand 60page reports is unrealistic. And stupid.

Posted

"Katen said .....My guess is that they're going to need to be told very basic stuff. Like the fact that a home inspection is visual, that we don't take stuff apart, that we can only evaluate what we see at the time of the inspection, that a typical inspection takes X hours. Even though they're educated people, they really aren't going to know this stuff until you tell them. Your tendency is going to be to talk way over their heads - keep it basic, at least at the beginning. After that, you might delineate the difference between a competent inspection and a "top10%" inspection."

That's what I'm trying to get at. No way am I going to try to explain specifics of inspecting. Impossible. I'm just trying to get down to a couple bullet point basics.

Key idea....."someone should be able to pick up a page at random, read it, and understand what's being said." Exactly.

Posted

Making the distinction between competent as SOP stuff and top 10% inspection is another useful point. Lots of competent operators just doing the SOP, not so many that understand the fine points.

How to discern those possessing the knowledge and acumen for the fine points?

What might an attorney ask while interviewing?

Posted

Just like HI's getting too cozy with Realtors, lawyers should be warned of the same thing. Many RE offices have their own in-house lawyer that they recommend to their client to make closings go smoothly.

Posted

I'm working with the directors of the real estate department at a couple of local (well known and respected) law schools to develop a set of criteria for new real estate attorneys in evaluating HI's.

This is not a "How To" class; that's not the point. It's how one might evaluate whether one's client is receiving a competent inspection.

2) What should a competent home inspection entail? Obviously State SOP and licensing stuff, but I want to go beyond that to get at the real stuff. I will continue to insist on things like inspectors actually climbing on roofs, or including common elements in condominium inspections.

3) We'll be talking about what "certified" means, and the intricacies of understanding the various HI professional society approaches to the game.

Hi Kurt,

Help me understand. Why are the new real estate attorneys going to be evaluating HI's? It sounds like they are evaluating HI's during the inspection process. Is this for potential future litigation against HI's, is this for referrals, or something else? If this is about litigation against HI's, I would not want to participate in helping you help them.

2) What is a competent inspection? Is the inspector moving around, observing and touching everything within reach, digging, probing and getting a workout, or is he having a brisk stroll through the home? Does the report contain a noticeable amount of filler and list mostly cosmetic items, or does it contain well-written and descriptive content of actual defects. Does the report contain clear and well-planned pictures with arrows for the sake of illustrating those defects?

Should inspectors pull the lid off the toilet tank? Once I started doing it I never stopped. Everything from tree frogs, to rigged flush kits to rust on the tank bolts. I put that in the category of being a digger.

You are holding firm on walking every roof. I disagree. I received a call from a client last week who asked if I walked her roof. I looked up the report and related that I did not walk the asphalt portion of the roof, but did walk the metal roof and used a ladder on the rest.

To paraphrase her response, she said something like: "Good, because my insurance company is concerned about any damage that may have been caused by someone (me) walking the roof." I try to walk any roof deemed safe to do so. I want to be clear, I have found many defects that I would have otherwise missed if I had not walked a roof. However, if I cannot for safety reasons, I have ladders, binoculars and a camera with a telephoto lens. One time, I damaged a soft and sticky roof with my boots during the hot summer. I may pony up for a drone to do the grunt work. I've seen some excellent results where only eagles dare to fly.

On 3), I think Bruce Ramsey offered something about Georgia Association of Home Inspectors requiring R-5 ICC Code Certification to become a full member. I believe this should be the minimum requirement should state licensing be required. That's what "Certified" means to me. Every inspector on the planet claims he's "Certified", right?

[:-propell[:-propell

Posted

Kurt, I think all the previous comments are good for you to consider.

Couple things stuck with me - Certified and being able to read any particular page and have an understanding of the issue. The "one page" concept is really a good idea that is new to me. I will apply it to our reporting.

The certified is very likely the most important issue with the attys. it goes to qualification and then on to expertise. Interesting that several inspectors think certified is a BS idea. Likely most on this board could not define certified, without help. Same is true for "master" inspector etc.

Isn't it really about being able to manage expectations? I think we are in trouble when we allow others to set the expectations, then expect us to validate them.

This would be a great roundtable discussion for the Road Show Symposium.

Posted

Key idea....."someone should be able to pick up a page at random, read it, and understand what's being said." Exactly.

To me that means a well written narrative style report that meets any governmental requirements. Back in the day (70's) an average home inspection could be well reported on in 4 or 5 pages of narrative. My recent experience with a formatted 85 page report with pictures left me with a headache. We have evolved to report on everything rather than the defects. The buyer wants to know what is wrong. They know what the place looks like.

Posted

Hank, this is about an attorney evaluating a HI's capability, not to sue them. Every transaction in Chicago has an attorney review. The professor and myself believe the whole mess is skewed with realtor influence and the attempt here is to provide attorneys with an idea of what they should be considering when reviewing a report or qualifying an inspector.

Debunking the Certified thing is a key line item.

Report structure is another. The entire "tap a PDA" report approach is a mess AFAIC; inspectors love them, which is an indictment in itself. I'm going to explain the concept of HI's writing comments specific to the house, not endless boilerplate constructions.

Process. Example.....Get on the roof. There's always someone with an excuse for why not. I'll explain the very few "why nots".

This isn't a How To seminar. It's a very general approach to evaluating an inspector with something more than realtor referrals, yelp, and Angie's List.

Posted

Whenever I do litigation support work I am asked to provided my CV. I am asked to provide my experience more than just the letters that follow my name. If I was an attorney recommending a home inspector, I would want this info before I recommend an inspector. The report format is important but would be secondary.

Added 7-18-14:

In explaining this to the attorneys and potential buyers I would make it an important point to educate them that a bad inspection/inspector cannot be overcome by a clear and concise reporting method.

Posted

If you want a definition of what is to be included in the report from a governing body, you will get something simple and ambiguous.

NC Realtors were bickering over what a material fact was to the point that the NC Real Estate Commission defined material fact as anything that could affect the purchasers decision to buy the property. WOW cover all those bases in the mind reading session.

A HI report should contain any (conditions, deficiencies... fill in the blank) that would affect the purchasers decision to complete the transaction.

I would not expect anything better from an attorney in Chicago or anywhere else.

Off to work!

Posted

My recent experience with a formatted 85 page report with pictures left me with a headache. We have evolved to report on everything rather than the defects. The buyer wants to know what is wrong.

Yep. I had to review one the other day that was 145 pages. Information scattered all over the place. Incomprehensible.

I'm actually getting a fair number of gigs nowadays entirely because of my format/structure. Folks call asking if I'm the guy with the "report using pictures to explain stuff".

Bruce's comments about licensing boards trying to develop report structure is so true. Buncha HI's and board members flailing. No idea where they should go, but by golly were gonna go there anyway.

The world has changed. How people read and comprehend has changed with it. HI reporting, for the most part, has not. It's gone the opposite direction.

Posted

Takeaway highlights so far:

1) Random report page selection should be readable and understandable.

2) HI CV, work history, experience.

3) What does Certification mean? Discussion of Professional Society approaches and the societies themselves. I promise to remain unbiased and factual.

3a) What does licensing actually mean? (not much outside of revenue stream for State, although I remain a proponent for licensing.)

4) Expectation management, both attorneys and customers.

5) Avoiding realtor/inspector/attorney all in bed together.

6) Difference between SOP inspection and "10%" top inspection.

7) General incompetence of State Licensing Board as overseer approach. It's rigged to the realtors and financial stakeholders. Understand that licensing boards aren't necessarily knowledgeable, and incapable of developing coherent reportage concepts.

This is the new generation. Not to go all in cynical, but my generation and the one under it started lost and will likely remain there, including almost all inspectors. We're trying to change the paradigm from the bottom up.

The professor's are all on board with the idea the current setup is rigged. They're hitting it from their end, I'll let them do that and add where I think appropriate.

Feel free to add to list.

Posted

Kurt, 3 and 3a are bothersome. I think you must go with a definition of terms. ie: an atty must read between the lines when viewing a cv. also I think some mention must be made of license vs registered vs certified vs etc. maybe quickly go thru how "regulation" takes many forms. That regulation is not and was not always formulated for consumer protection.

BTW your third from last paragraph does not make sense to me.

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