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ASA, 25 Other Organizations Write to Oppose TriStar Bank Appraiser Waiver Request

Apr 09, 2018

On April 9, the American Society of Appraisers along with 25 other national and state appraiser organizations – filed comments with the Appraisal Subcommittee expressing their opposition to the appraiser waiver request filed by TriStar Bank. In the letter, the groups emphasize the lack of an support for TriStar’s request among 37 informal comment filed prior to the opening of the formal notice-and-comment process, as well as the fact that TriStar’s claimed shortage of appraisers was contrary to several readily available registries and lists.

The letter goes on to criticize TriStar’s lack of urgency in perfecting an actionable request, as well as its seeming indifference to appraisers who attempted to get on TriStar’s approved panel for performing appraisal assignments. Were the request to be granted, TriStar – along with every other lender doing business in the Nashville, TN MSA – would be exempt from using appraisers to perform appraisals in connection with federally related transactions; this would not, however, obviate the requirement to get appraisals.

To read the full comment letter to the ASC, click here. The following organizations joined ASA is signing the letter:

American Society of Farm Managers and Rural Appraisers
Appraisal Institute
Appraiser's Coalition of Washington
California Coalition of Appraisal Professionals
Coalition of Appraisers in Nevada
Coalition of Arizona Appraisers  
Illinois Coalition of Appraisal Professionals
Louisiana Real Estate Appraisers Coalition
Maryland Association of Appraisers
Michigan Coalition of Appraisal Professionals
Mississippi Coalition of Appraisers
National Association of Independent Fee Appraisers
New York Coalition of Appraisers
North Carolina Real Estate Appraiser Association
Northern Colorado Association of Real Estate Appraisers
Ohio Coalition of Appraisal Professionals
Oklahoma Professional Appraisers' Coalition
Real Estate Appraiser's Association, California
Real Estate Appraisers of Southern Arizona
Rhode Island Real Estate Appraiser Association
South Carolina Professional Appraisers Coalition
Tennessee Appraiser Coalition
United Appraisers of Utah
Virginia Coalition of Appraiser Professionals
West Virginia Council of Appraiser Professionals

If you have questions or wish to discuss ASA’s views further, please contact John D. Russell, JD, Senior Director of Government Relations and Business Development for ASA at, or by phone at 703-733-2103.