- Jan 16, 2002
- Professional Status
- Certified General Appraiser
The letter says, in part
HUD Should Not Issue Proposed Regulations Relative to the Appraiser Watch Initiative
HUD wants to establish a clear, consistent and familiar standard and procedure for an appraiser to maintain status on, or be removed from, the FHA Appraiser Roster. NAR shares this goal with HUD, but disagrees that the Appraiser Watch Initiative is the way to achieve this objective. As we indicated in our joint comment letter with the Appraisal Institute and the American Society of Appraisers, we would strongly encourage HUD not to go forward with the Appraisal Watch Initiative because of the following reasons which are expounded upon in the joint comment letter:
1. Loan defaults are caused by factors beyond the control of the appraiser.
2. Appraiser Watch does not address poorly performing appraisers whose appraised loans do not end up in default.
3. Appraiser Watch does not establish a system of proximate cause for default.
4. Appraisers, loan officers and underwriters have different functions; therefore, their performance should not be based on the same criteria.
5. There may be unintended consequences of a default-based Appraiser Watch system.
6. Appraiser Watch does not address lender accountability for appraisals.
7. Appraiser Watch fails to address inappropriate client pressure on appraisers.
8. Appraiser Watch fails to address historical failures of HUD management systems.
9. HUD’s elimination of the Appraisal Quality Assessment (AQA) process appears not to have been justified.
10. Appraiser Watch fails to curb appraisal problems before they occur.