March 14, 2022 — The National Association of State Credit Union Supervisors (“NASCUS”) submitted a letter in response to the Appraisal Subcommittee (ASC) of the Federal Financial Institutions Examination Council (FFIEC) proposal to amend existing rules of practice and procedure governing temporary waiver proceedings.
The ASC’s proposed amendments are intended to provide greater transparency and clarity to temporary waiver proceedings pursuant to Section 1119(b) of Title XI of the Financial Institutions Reform, Recovery, and Enforcement Act of 1989. A properly calibrated and equitable appraisal waiver process is essential to mitigate the dire effects that a regional scarcity of qualified appraisers can have on the provision of credit to consumers related to real estate transactions.
NASCUS welcomes efforts to enhance the waiver process and we commend the ASC for undertaking this important initiative. However, as discussed in the comment letter, the changes as proposed would likely diminish the practical effectiveness of the Section 1119(b) appraisal waiver process rather than strengthen it.