The OCC, FRB, FDIC, OTS, and NCUA (the Agencies), has requested comment on the proposed Interagency Appraisal and Evaluation Guidelines (proposed Guidelines).
The proposed Guidelines, which would supersede the 1994 Interagency Appraisal and Evaluation Guidelines (1994 Guidelines), reflect revisions to the Uniform Standards of Professional Appraisal Practice (USPAP) and the evolution of collateral valuation practices, such as the use of automated valuation models (AVMs).
The proposed Guidelines also incorporate refinements made by the Agencies to the supervision of regulated institutions’ appraisal and evaluation programs since 1994 and reflect the participation of the NCUA, which was not a party to the 1994 Guidelines. The proposed Guidelines are intended to clarify the Agencies’ real estate appraisal regulations and promote a safe and sound real estate collateral valuation program.
The Illinois Real Estate Appraisal Board has issued their "preliminary" response in a letter dated December 31, 2008 - Download IL_Comment_Docket_ID_OCC20080021
The document addresses the " . . .first three of a number of findings the Illinois Appraisal Board has adopted . . .":
- Finding One - Client and Intended User Issues
- Finding Two - The Issue of Agent's Authority
- Finding Three - Delivery of Appraisal
Finding three addresses the problem of AMCs and Delivery Portals not providing a "True Copy" of the original appraisal report:
The Board’s has become aware that some AMC’s and /or Internet delivery portals do not provide “true copies” of delivered appraisal reports to their clients or other intended users. This can result in clients/intended users receiving non-credible or even misleading reports. A “true copy” is an exact duplicate of the written document.
While The Board recognizes appraisers have no control over what happens to their reports after they are delivered, The Board’s position is that appraisers may not be complicit in facilitating the delivery of other than “true copies” of the report.
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