The Appraisal Complaint National Hotline
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Jim Park, the Executive Director at the Appraisal Subcommittee (ASC), gave an informative presentation at Valuation Expo this past June. In this session, Jim reviewed the functions and oversight duties of the ASC and current status and regulatory issues with the States. One of the more interesting topics covered in Jim’s presentation regarded the Appraisal Complaint National Hotline, which was established in accordance with the Dodd-Frank Act, put into law July of 2010.
TThe National Hotline, which began taking referrals in March of 2013, acts only as a facilitator for complaints. In other words, the National Hotline identifies the Agency(s) to which the complaint is made through a series of questions on the referral form. The referral form can be completed on the ASC website, over the phone, or by Email.
From Jim’s description, the key to a successful outcome of a complaint is to first determine the complaint type. The hotline is responsible for two types of complaints, USPAP and/or Appraisal Independence. Jim noted the website offers resources to assist in accurately determining the nature of a complaint, as well as other helpful information.
The Director further clarified what the ASC and the National Hotline will not do for the complainant, including: initiating a complaint, acting on behalf of the complainant, arbitrating the complaint, assisting in appealing the outcome of a complaint, or following up on a complaint.
Here are some findings of the National Hotline to date:
- 3,075 complaints have been filed
- Complaints to State agencies and Federal agencies have totaled 450 and 175, respectively
- Appraisal independence complaints comprise 53%, while USPAP complaints are 47%
- The largest percentage of complaints are filed against appraisers (versus lenders, AMCs, or real estate agents) at 61%
- Who complains the most: 43% borrower or purchasers, 42% appraisers, 6% AMC’s, and 5% lenders.
- The Agencies receiving the majority of complaints include the CFPB at 79%, with all the remaining Agencies like the FTC, Federal Reserve Board, and regulators like the Office of Comptroller of Currency, FDIC and the NCUA in single-digit percentages.
- The five states with the greatest number of complaints are: AL, CA, KY, TX and IL. Jim considered CA, TX and IL as logical recipients due to their population size, but he was unsure why AL and KY were high on the list.