(Professional Farm Managers) Agronomics Annual Meeting, Indian Wells, CA; www.
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.
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.
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.
AI and ASFMRA asked that the final rule incorporate provisions relating to appraisal review and second appraisals, rather than imposing a lower combined loan-to-value ratio that may unnecessarily constrain credit.
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.