Re: FHFA RFI on Appraisal-Related Policies, Practices and Processes, December 28, 2020
Federal Housing Finance Agency
Office of Housing and Regulatory Policy
400 7th Street SW, 9th Floor
Washington, D.C. 20219
Remitted to: [email protected]
Dear Director Calabria,
The American Bankers Association (ABA) appreciates the opportunity to comment on the Federal Housing Finance Agency’s (FHFA) Request for Information on Appraisal-Related Policies, Practices, and Processes (RFI). ABA believes it is critical for Fannie Mae and Freddie Mac (Enterprises or GSEs) to consider feedback from all users in the industry when implementing new valuation products, the use of Automated Valuation Models (AVMs), Appraisal waivers, and the Uniform Appraisal Dataset (UAD) and redesign changes that will ultimately impact borrowers’ access to credit. ABA fully supports creating new alternatives to the traditional appraisals available in the market today. We believe new technology and tools need to be forward thinking in order to support a variety of valuation alternatives to enable lenders to offer a range of options to serve borrowers across the spectrum of loan types originated. These tools will help lenders serve all credit markets despite the capacity constraints in the availability of appraisers.
We ask, however, that prior to rolling out the new consolidated appraisal form, FHFA direct the GSEs to carefully consider costs and benefits associated with these changes, including the costs to industry arising from the implementation of the modifications to residential forms. Although a full revision of existing forms may help streamline the narrative section for some appraisal formats, the need for many expanded fields has not been fully established, and the actual cost and time to implement remain unascertained. We appreciate FHFA issuing the RFI and encourage the agency to continue to work with stakeholders to ensure that any changes ultimately adopted achieve their objectives while minimizing costs and potential disruption to the market.
Download the comment letter to read the full text.
