In what can only be viewed as a victory for the appraisal community, the Appraisal Subcommittee (ASC) voted at its April 23, 2018 meeting to deny the request of TriStar Bank for a waiver from the federal regulatory requirement to utilize a licensed or certified appraiser for appraisals performed in certain counties in the Nashville, Tennessee area.
TriStar had formally requested the waiver in November of 2017, claiming there was a shortage of appraisers in their lending area and stating that appraisal turnaround times and fees had risen between 2013 and 2017. If granted, the waiver would have permitted TriStar to use non-licensed or non-certified individuals (e.g., real estate agents, brokers, bank employees, etc.) to perform appraisals within the Nashville MSA for the bank. It would not have eliminated the bank’s requirement to obtain appraisals in connection with loan applications.
According to sources, the ASC determined that the data provided by TriStar did not demonstrate a “significant” delay, and the data also failed to demonstrate an appraiser shortage. Comments made during the meeting indicated that ASC members were not convinced of significant delays in appraisal completion times. During the meeting, it was also indicated that a number of Tennessee licensed and certified appraisers had applied to TriStar’s appraiser panel, yet very few were actually accepted.
The ASC is made up of representatives from the four federal financial institution regulatory agencies (OCC, FRB, FDIC, NCUA) plus representatives of FHFA, HUD, and the CFPB.
Article by Dan Bradley. Daniel A. Bradley, SRA, CDEI is the Director of Online Appraisal Curriculum for McKissock Learning. He has been a practicing real property appraiser since 1987, and has been instructing and authoring appraisal courses since 1992. He is a state certified general appraiser in Pennsylvania and is currently on the FHA appraiser roster. From 2004 to 2013, Dan was a member of the Pennsylvania State Board of Certified Real Estate Appraisers, serving for five years as vice-chairman and three years as chairman. He has also has served as a contracted expert witness appraisal reviewer for the Pennsylvania Department of State.
