* Accepted a report from the Educational Programs and Publications Committee on progress toward education reciprocity with ASA and ASFMRA
, the potential for exploring jointly developed basic curricula and cooperative effort on The Dictionary of Real Estate Appraisal.
In their joint letter, AI and ASFMRA
asked HUD to withdraw the provision that would eliminate the requirement for a real estate appraisal, and criticized the agency for claiming that there aren't enough state-certified appraisers without citing any research to support that claim.
While the sales contract should stipulate who's responsible for the assessment, AI and ASFMRA
said that disclosures of existing PACE loans should be required and that appraisers should be responsible for confirming existence of the loans.
The Appraisal Institute and ASFMRA
consider the section to be in conflict with current Real Estate Lending guidelines, as well as the Interagency Guidelines, and further point out that, under current policy, a reappraisal on performing loans is not required anyway except in cases of safety and soundness concerns.
In their letter, AI and ASFMRA
cited recent research from the National Association of Realtors that said borrowers are now paying higher appraisal fees but appraisers are earning reduced fees, sometimes by as much as 40 percent.
View the joint AI/ ASFMRA
letter at: www.appraisalinstitute.org/newsadvocacy/downloads/Itrs_tstmny/2012/AI-ASFMRA-Statement-HR3461.pdf.
In addressing the "skin in the game" issue, AI and ASFMRA
expressed support for full appraisal requirements relating to commercial real estate and the proposed six-month "shelf life" for commercial real estate appraisals.
In the second instance, AI and ASFMRA
responded to the FHFA's request for comments on the current residential REO market, specifically on management and disposition strategies.
5 letter, the AI and ASFMRA
implicitly asked the department to "suspend the effort to extend fiduciary status to real estate appraisers given that they do not provide 'investment advice,' and in light of the many enforcement outlets that protect the appraisal profession and users of appraisal services."