ASA/ NAIFA/ ASFRMA Letter to House Financial Services Subcommittee Urges Federal Agencies’ Reliance on Credentialed Appraisers, Criticizes Loophole In Federal Reserve Proposed Rule

On August 4th, ASA, joined by the National Association of Independent Fee Appraisers (NAIFA) and the American Society of Farm Managers and Rural Appraisers (ASFMRA) sent a letter to the House Subcommittee for Insurance, Housing, and Community Opportunity, expressing their views regarding the Subcommittee’s July 13 “Mortgage Origination” hearing.
 
In the letter, ASA, NAIFA and ASFMRA asserted that professional appraisals provide a “critical safety and soundness and consumer protection”, and pointed to a recent Government Accountability Office (GAO) report concerning real estate appraisals in support of the role played by appraisers in the underwriting process. The GAO found that real estate appraisals “play a critical role in mortgage underwriting by providing evidence that the market value of a property is sufficient to help mitigate losses if the borrower is unable to repay the loan”.

The letter also addressed the Federal Reserve Board’s implementation of the Appraisal Independence Provisions of Dodd-Frank, describing its Interim Rule as being flatly incompatible with the statutory requirement of Dodd-Frank that appraisers be paid customary and reasonable fees that exclude consideration of fees paid by AMCs to appraisers.

The letter also voiced serious disagreement with the criticisms leveled by the Appraisal Institute (AI) against The Appraisal Foundation (TAF) and the Federal Appraisal Subcommittee (ASC). The letter states that ASA, NAIFA, and ASFMRA firmly back TAF, arguing that its work is a fundamental asset to the continued growth of appraiser professionalism and the reception by federal and state agencies of Uniform Standards of Professional Appraisal Practice (USPAP). The letter goes on to voice support for the newly created Appraisal Practices Board (APB) of TAF, stating that the need for a uniform set of best practices for the professional real estate appraisers (particularly the roughly 70,000 unaffiliated appraisers) is critical.

The letter did, however, also concur with AI’s assessment of the ongoing implementation of the Dodd-Frank Act, specifically as it relates to the issues of customary and reasonable fees, separate fee disclosures on the HUD-1 form, and the use by Fannie Mae and Freddie Mac of the Uniform Appraisal Dataset (UAD).
 
About ASA
The American Society of Appraisers is an international organization of appraisal professionals and others dedicated to the education, development and growth of the appraisal profession. ASA is the oldest and only major organization representing ALL disciplines of appraisal specialists, originating in 1936 and incorporating in 1952. ASA’s headquarters is in the metropolitan Washington, D.C. area. To find an accredited appraiser near you, visit http://www.appraisers.org or call (800) 272-8258.

Christy Jones
American Society of Appraisers
(703) 733-2124

Source:  Reston, VA (PRWEB) August 15, 2011