Five groups with a stake in the rules governing real estate valuation have voiced their opinions on the proposed federal Interagency Appraisal and Evaluation Guidelines announced in November 2008.
First, the American Society of Appraisers, the American Society of Farm Managers and Rural Appraisers and the National Association of Independent Fee Appraisers stated in a joint letter that the proposed requirements “actually weaken, rather than strengthen, the safety and soundness of real estate loans made by regulated institutions.”
Two of their complaints included:
- The guidelines exempt a dozen categories of real estate lending transactions from the Title XI requirements.
- The rules would permit the use of “untested and unreliable alternatives” to appraisals (i.e., automated valuation models, broker price opinions and property tax assessment valuations) to substitute for the opinions of certified or licensed appraisers.
Two other groups, the Apppraisal Institute and the Title Appraisal Vendor Management Association, have issued public statements, as well. See the full story at Valuation Review for their feedback on the proposals.