Appraisal Institute calls for modernization of appraisal regulatory structureMortgagePress.comAppraisal Institute, Senate Banking Committee, Title VII, HR 3915, Mortgage Reform and Anti-Predatory Lending Act
The Appraisal Institute has submitted a joint industry letter to
the Senate Banking Committee advocating revisions to deficiencies
in the appraisal regulatory structure. Specifically, the Appraisal
Institute urged the Senate to adopt Title VII of House Resolution
3915 (HR 3915), the Mortgage Reform and Anti-Predatory Lending Act,
which would allot greater resources to state appraisal boards for
enforcement activities while increasing the effective oversight
authority of the Appraisal Subcommittee.
The letter, cosigned by the American Society of Appraisers,
American Society of Farm Managers and Rural Appraisers and the
National Association of Independent Fee Appraisers, came in
response to a recent Associated Press expose highlighting the
shortcomings of Title XI of the Financial Institutions, Reform,
Recovery and Enforcement Act of 1989. Title XI is the legislation
that contains the provisions that govern the appraisal regulatory
"We have been deeply troubled by the lack of responsiveness by
some federal and state appraiser regulators in carrying out Title
XI responsibilities," said Bill Garber, director of government and
external relations for the Appraisal Institute. "We hope the recent
attention to weaknesses in the appraisal regulatory structure
proves to be a catalyst for the passage of HR 3915 and the
subsequent modernization of Title XI."
The Appraisal Institute expressed its concern over the following
areas of Title XI, which the organization has stated are in need of
• The Appraisal Subcommittees lack of enforcement
authority over state appraisal boards.
• The Appraisal Subcommittees lack of resources for
conducting investigations and enforcing rules.
• The lack of penalties for parties who attempt to coerce
appraisers to meet a predetermined opinion of value, thus
jeopardizing the integrity of the real estate transaction.
• The current appraisal "de minimis," whereby transactions
below $250,000 are exempted from Title XI's appraisal requirements,
which according to the Appraisal Institute, "exposes consumers to
unregulated valuation products."
"The appraisal profession is ever-changing and dynamic,"
explained Garber. "As such, legislation governing the profession
needs to adapt to the times in order to ensure the best interests
of the public are protected. We believe that Title VII of H.R. 3915
protects those interests and urge the Senate to pass this
HR 3915 was voted through the House with strong bipartisan
support. Currently the bill is pending in the Senate Banking
Committee. For more information on the comment letter sent to the
Senate Banking Committee, visit the News
and Advocacy section of the Appraisal Institutes Web site.
For more information, visit www.appraisalinstitute.org.