Appraisal Hotline Operations Details
Appraisal Institute Wants Details on Appraisal Hotline Operations
The Appraisal Institute and the American Society of Farm Managers and Rural Appraisers jointly sent a letter Feb. 12 to the Appraisal Subcommittee asking that it make its proposed protocol for operating the “appraisal hotline” available for public comment prior to its March 29 implementation.
In the letter, AI and ASFMRA said that while the concept of a hotline is sound, there exists almost no understanding among state appraiser regulatory officials, practicing appraisers and real estate and mortgage professionals as to how the hotline would function or even of its intended purpose.
The ASC announced its intent to consider (and potentially approve) a draft protocol to provide contact information for regulatory agencies related to complaints regarding appraisal independence issues and concerns over the Uniform Standards of Professional Appraisal Practice.
AI and ASFMRA requested that the ASC refrain from approving the protocol and instead release it for public comment similar to the process used by the ASC in drafting Policy Statements.
Joint AI-ASFMRA letter below:
Dear Chairman Gillespie:
On behalf of the 25,000 members of our respective professional appraisal organizations, we respectfully request that the Appraisal Subcommittee (ASC) expose for public comment the proposed protocol for carrying out the appraisal independence “Hotline” prior to implementation.
We understand that at its February 13 meeting the ASC intends to consider – and potentially approve – a draft protocol to provide contact information for regulatory agencies related to complaints regarding appraisal independence issues and concerns over the Uniform Standards of Professional Appraisal Practice (USPAP). The hotline intends to refer individuals to the appropriate regulatory agency, rather than compile the complaint on behalf of the individual and refer it to the appropriate agency. For example, if an appraiser has a complaint regarding mortgage broker influence on the appraisal process, the appraisal hotline intends to provide the appraiser with the contact information of the appropriate regulatory agencies – in this case, the Consumer Financial Protection Bureau and the state mortgage licensing agency. Likewise, consumers who have complaints regarding USPAP
compliance will be provided contact information for the appropriate state appraiser regulatory agency and/or the appropriate bank regulatory agency if the matter involves a federally regulated institution.
The concept of a hotline is well founded, given the multitude of individuals who attempt to assert influence on the appraisal process and the overlapping regulatory structures involving mortgage and real estate professionals. For many years, the Appraisal Institute has maintained a website whereby appraisers and others could refer complaints to appropriate regulatory agencies. The Dodd-Frank Act recognized the importance for such an endeavor, authorizing the ASC to implement an actual hotline in the absence of one being established by the private marketplace.
However, in speaking with state appraiser regulatory officials, practicing appraisers and others involved with real estate and mortgage finance, virtually no understanding of the hotline and its intended purpose, as well as the proposed protocol, exists. As such, we believe that the protocol could be met with unnecessary trepidation simply because to date the ASC did not seek stakeholder input. As such, we respectfully request that the ASC refrain from approving the protocol, and instead release the protocol for public comment, similar to the process used by the ASC in drafting Policy Statements. Since the appraisal hotline likely will impact other mortgage and real estate professionals and regulatory agencies, we believe that all stakeholders deserve to have an opportunity to review and Appraisal Independence “Hotline” February 12, 2013 comment on the hotline before it is operational. This is the foundation of good government and, in this case, we believe that such a measure actually will engender support for the proposed protocol.
Thank you, in advance, for your consideration of our request. Should you have any questions or require additional information, please contact Bill Garber, Director of Government and External Relations, Appraisal Institute, at 202-298-5586 or bgarber AT appraisalinstitute DOT org, or Brian Rodgers, Manager of Federal Affairs, Appraisal Institute, at 202-298-5597 or brodgers AT appraisalinstitute DOT org.
American Society of Farm Managers and Rural Appraisers