December 20, 2012 (Reston, VA) On December 18, ASA, along with the National Association of Independent Fee Appraisers, filed comments with several federal agencies regarding the implementation of the National Appraiser Complaint Hotline, as required by the Dodd-Frank Act. The rulemaking, dealing with Paperwork Reduction Act (PRA) issues raised by the new hotline, was jointly issued by the Office of the Comptroller of the Currency (OCC), the Federal Deposit Insurance Corporation (FDIC), and the National Credit Union Administration (NCUA).
In their comments, ASA and NAIFA urged the agencies to stay true to the intent of the hotline, which is to allow for reporting of instances where appraiser independence has been impeded, and not become a “catch-all” for every appraisal complaint. Further, the comments stress that reports to the hotline should not trigger costly and burdensome investigations of appraisers that are unrelated to appraiser independence issues. ASA and NAIFA also asked that hotline complaint data be shared with stakeholders, but be scrubbed of confidential or sensitive identifying information unless a formal enforcement action has been taken by an agency. Finally, the comment letter asked that federal agencies consider the impact to state appraiser boards when calculating the hotline’s total burden, given that many complaints will involve a state, as well as federal, component.
To read the full text of the comments filed by ASA and NAIFA, click here.