ASA, Other Appraisal Groups File Comments on FHFA Fair Lending Oversight Data System

June 21, 2022

On June 21st, ASA submitted formal comments to the Federal Housing Finance Agency (FHFA) in response to the new system of records titled the “Fair Lending Oversight Data System”. The system will be used to store, maintain, and analyze information for fair lending oversight of Fannie Mae and Freddie Mac, and includes appraiser name and license number among the data to be stored or accessed in the system.

Along with the Appraisal Institute, American Society of Farm Managers and Rural Appraisers, and MBRES, ASA has concerns with how the data will be shared and the purposes for which data is exchanged. Specifically, the concerns revolve around individual data privacy issues and the need for data to holistically represent the nature of appraisals that support housing finance transactions.

The organizations further call on the FHFA to use this new data system to study the effects of automated underwriting and review systems commonly used by the GSEs on the availability of credit in minority communities and the subsequent impact on their home values in order to make better-informed enforcement decisions.

To read the letter, click here