“TARRANT APPRAISAL DSTRICT 'BORRD OF DIRECTORS 2500 Handley-Fderville Road Fort Wort, Texa: April 10,2023 Jef Law, Coie Appraiser RE Letter of Rep Dear Mr. Law, Many aspects of the Tarrant Appraisal District are operating very wel and at avery high level. The most recent Methods Assistance and Procedures audit by the Texas State Comptroller gave the Tarrant ‘Appraisal District a perfect 100% score. Silat, the Texas State Comptroller's Property Value Study has consistently found thatthe appraised values certified bythe Tarant Appraisal District have al been within the 5% margin of eror. The Tarrant Appralsal District is one cf the few Appraisal Districts inthe State of Texas to receive the Cerificate of Excellence in Assessment of Administration awarded by the International Association of Assessing Officers. The Tarrant Appraisal District has been listed as one of, ‘the best places in Fort Worth to work. Most importantly, the Taran: Appraisal District's appraisal rolls have been certified tothe Tax Assessor Collector na timely and acctrate manner. However, as we discussed atthe March 17, 2023 meeting, The Boare of Directors ofthe Tarrant Appraisal District is issuing this letter due to several reoccurring issues with the Tarrant Appraisal District. There have been several recent incidents that have adversey affected the creaibilty of the Tarrant Appraisal District. As the Chet Appraiser, itis your responsitility to ensure that ll functions of ‘the Appraisal District are performed ina manner that instil the pubic with confidence inthe Appraisal District. Your Diector of Residential Appraisal, Randy Armstrong, fed four complaints against a local tax agent With the Texas Department of Licensing and Regulation between October and December of 2021. The ‘complaint were fled in a manner that caused the Texas Departmen: of Licensing and Regulation to believe the complaints were fed bythe Tarrant Appraisal District. Additionally, the complaints were fled using resources that belong to the Tarrant Appraisal District. You informed the Board of Directors that you were unaware thatthe complaint had been led by Mr. ‘Armstrong uni the complaint was brought to your attention in November of 2021. The Board of Directors views ths as failure of management. Your management team and staf should understand that the fling ofa formal complaint that appears tobe from the Tarrant Appraisal District without {approval ofthe Chief Appraiser and senior managements prohibited. A well-managed staff would not have taken thisindependent step that resulted in the los of time, resource, and credibility to the Tarrant Appralsal District. ‘You were frst informed about the complaints in November of 2021. n your inital investigation you did not inquire as to whether the complaint was filed by Armstrong individually, or asa representative of the Tarrant Appraisal District. Nor di you inform any member of the Board of Directors that Mr Armstrong had filed the complaints. Asa result, the Bard of Diecters was caught completely off guardwien a local attorney sent letter to the Board of Directors on May 12,2022 lalming that the complaints violated the local tax agents Ftst Amendment right to petition the government. The Board of Directors views this asa fallure of communication ‘Once you were aware that there had been 2 complaint fled agains a local ax agent by your staf you should have taken steps to learn the facts surrounding the complaint and communicated those facts to ‘the Board of Directors. The failure to adequately investigate and communicate this Issue tothe Board of Directors caused a local attorney to threaten legal action against the Tarrant Appraisal Dre, resulted Ina loss of confidence in the Tarrant Appraisal District in the eyes ofthe public and made the Board of Directors look lke they were not informed of important sues relating tothe Tarrant Appraisal District. (On June 30,2022, the Tarrant Appraisal District had a special called meeting to discus the May 22, 2022, letter sent by the tax agent’ attorney. The special called meeting was held during the Appraisal Review Board season. Asa result, the normal meeting space for Board of Dcectos' meetings was not available, Inthe days leading up tothe meeting thee were several indications that there would be ‘many members of the public attending the meeting. On the day ofthe meeting, over 100 citizens showed up wanting to attend the meeting. The meeting room that was avaiable held fewer than 20, people. As result, many people who wanted to attend the meeting were unable todo so, ‘Additionally, many ofthe people who wanted to attend the meeting were forced to wat outside in the ‘summer heat. The allure to have a plan to adequately deal withthe numberof people who showed up resulted in extremely negative press coverage forthe Tarrant Appraisal istrict, investigations by the District Attorney's Office into possible Open Meetings Act violations, and many very upset members of the public In addition to the issues relating to the complaints that were ied by your staff, there have been several other issues negatively impacting the credibly of the Tarrant Appraisal District. Some ofthese sues revolve around the computer systems and website used bythe Tarrant Appraisal District. ‘Many aspects ofthe Tarrant Appraisal District website were unavailable during the lst few months of 2022 and the early part of 2023, This was due toa security upgrade being performed bythe Tarant ‘Appralsal District. Asa result, many tax agents and property owners were notable to access information that is normally available tothe public, This unavailability occurred during the same time that many other appraisal districts nthe State were impacted by ransomware attacks. Communication ‘with the public regarding the status ofthe Tarrant Appraisal District computer systems coud have been better. Specifically, communication with the public about what aspects ofthe website were available {and functioning, and what aspects ofthe website were not avalable and functioning was inadequate, ‘Te lack of communication resulted in confusion and misinformation about whether the website would be functional again, and when the information would be avaiable to the public again, Similarly, there have been concerns about whether the online protest portal wil be avaliable for use in ‘the 2023 Appraisal Review Board season. You informed the Board of Directors that you plan to have the ‘online protest portal up and running by the time protest season starts. The Board of Directors expects ‘thatthe online protest portal wil be fully operational and statutorily compliant by the time notices of appraised value are mailed. Thisis necessary to ensure that all tax agents and property owners can {gather and review all the information they need to determine whether a protest on thelr property is appropriate‘Adsitionally, there have been several complaints made during the pubic comment portion ofthe Board ‘of Directors’ meetings expressing concern about the way that homestead exemptions, and specially ‘Over 65 homestead exemptions, are managed. The Board of Directors expects your staff to investigate and respond to each ofthese property owners to ensure not only that their exemptions were pracessed correctly, but also thatthe property owner understands why thee tax talus is what tis. Additionaly, procedures shouldbe implemented to ensure that homestead exemptions are managed in an appropriate manner. ‘Tere have also been questions asked about whether itis a conflicof interest for realestate agents oF brokers to be employed by the Tarrant Appraisal District. The Board of Directors voted to create a subcommittee consisting of Jeff Craig, Director Martinez and the Board's attorney to suggest revisions to the Tarrant Apprlsal District's Conflict of Interest policy. We expect thatths policy wil be revised, and that you wll ensure thatthe revised policy is complied with by all Tarrant Appraisal District employees The issues outlined in this eter have resulted ina loss of confidence and cediblty in the Tarrant Appraisal District. Several taxing units that participate in the appraisal drt exercised their option to recallformer Chair Kathryn Wilemon. The handling ofthe recall resulted i addtional adverse media ‘overage and public outery. Some ofthis is due to a confi in the vacancy and appointment provisions ‘ofthe Tax Code. The Board of Directors would lke you to vist with members ofthe Texas Legislature and other state officials, including the Comptroller, to inform them ofthe potential conflict between Texas Tax Code, section 6.03) and 6.033, Specifically, the Goard of Drecors would like to see a revision ofthe Tex Code that eliminates the vacancy provision of section €.03() and provides thatthe taxing units select a replacement member for any vacancy. The Tarrant Aoprasal District Bard of Directors should not select its own members, Those members should be selected by the taxing units Final, there have been questions about the way the recall ofthe Board of Oiectors' former chal was handled. The letter you sent tothe taxing units indicated that upon the former chal’ esignation, the recall election was cancelled. Similarly there was no clear communiatio tothe entities about the process that would be used to fill the vacant position on the Board after the Board of Directors voted to fellow the recal process of 6.033 rather than the vacancy process of 6.03). Additionally, you showed, Lup at the Mansfield City Councll meeting where they were voting onthe real ofthe Board of Directors former char. This appearance was seen by some as meddling inthe vote. These ssves have also resulted ina las of confidence and credibility in the Tarrant Appralsa District by at east one member of the Texas Legislature, Representative Charie Geren has file 3 bill to abolish the Tarrant Appraisal Dstt. Better communication with our local elected lenders may have avoided the filing ofthis il and may prevent it from ultimately getting passed into la. ‘The Board of Directors expects each ofthese lsues tobe repaired. Specifically the Board of Directors ‘expects you to 1), Develop and implementa plan to repair the credibility and reputation ofthe Tarant Appraisal District 2} create a culture, to include enforcing policies and procedures that ensure, that Tarrant ‘Appraisal District staff donot retaliate against any property owner o tax agent;3) Be aware of issues that arse inside the Appraisal District, investigate allegations of wrongdoing within the Appraisal District and keep the Board of Directors informed of any potential issues hich could result in questions from the members ofthe public or the media; 4) Communicate appraisal district issues affecting tax agents, members ofthe publc nd Participating taxing units to the affected stakeholders in a complete and timely manner; 5), Develop procedures and recommendations to the Board of Directors to ensure that public ‘comments are conducted ina timely and efficient manner, and that the public and media have access tall Board of Directors’ meetings, including overflow rooms and remote video access; 6). Ensure that all Tarrant Appralsal District computer systems and website work propery and in compliance with statutory requirements, and that any deficiencies are fixed ina timely manner and communicated tothe pubic 7) Enforce the revised Tarant appraisal District conflict of interes polly; 8). Respond to al ctizen, mea and othe stakeholders’ inquiries and concerns ina timely manner; 9}. Implement all leislative directives to appraisal districts in the time and manner required bylaw; 30) Advise the legislature of the potential conflict between Texas Tax Code, sections 6.030) and 6.033; and 11) Avoid creating the appearance that you are participating in the political discussions regarding win will serve onthe Tarrant Appraisal District Board of Directors. ‘The Board of Directors is giving you 90 days to rectify the isues that are outlined inthis letter, Failure to resolve these issues may result in further corrective action up to and including dismissal. 1fthere are any resources o assistance you need from the Board of Directors to rectify these deficiencies, let us know. Thank you, Tarrant Appraisal District Board of Directors