Appraisal Complaint Hotline Usage
Four Reasons Why ASA & NAIFA Urge Appraisal Subcommittee to Delay Rollout of National Appraisal Complaint Hotline
On February 6 ASA, along with the National Association of Independent Fee Appraisers (NAIFA), sent a letter to the Appraisal Subcommittee (ASC) urging them to delay the planned March 29th implementation of the national appraisal complaint hotline, as required by the Dodd-Frank Act. In pushing for the delay, ASA and NAIFA pointed to several issues regarding the hotline’s formation:
- That the appraisal complaint hotline was created in a closed process, without adequate stakeholder exposure or input;
- The hotline, as proposed, violates Congress’s intent and the clear language of Dodd-Frank;
- The hotline has morphed from a tool for appraisers to report instances of undue influence into a “catch-all” tool where anyone can file a complaint against an appraiser for any alleged violation of USPAP, regardless of whether it is legitimate; and,
- The open-ended cipher design of the hotline will greatly increase the volume of complaints against appraisers, impose undue, excessive burdens on them and on state appraiser licensing agencies, and possibly gum up the mortgage loan processing system. Ironically, the open-ended hotline is likely to increase pressure on appraisers to come up with market values that will make a mortgage transaction appear to be safely collateralized.
On February 7, government relations representatives for ASA and NAIFA met with Jim Park, Executive Director of ASC, along with senior staff, to further discuss the letter’s contents and to request an opportunity for the two organizations to be heard by the full ASC board.
Full letter sent to ASC below.
We understand that the ASC intends to monitor how the hotline system is functioning and, presumably, make adjustments as necessary in the future. This approach overlooks the fact that even with course corrections, the hotline (as conceived in a closed process) will start out as a far inferior product than it would have been had stakeholders been involved during its conception. Fixing a flawed or broken program after-the-fact is not as cost-effective as, and is not a substitute for, doing everything reasonably possible to perfect the program before it is rolled out.