The Appraisal Institute and the American Society of Farm Managers and Rural Appraisers jointly sent a letter Feb. 28 to the Federal Deposit Insurance Corporation, the National Credit Union Administration and the Comptroller of the Currency expressing concern about the broad reach of a proposed Interagency Appraisal Complaint form.

The agencies intend to provide a copy of the form to individual complainants, who, in turn, will return to the agency for information gathering and potential referral.

In its letter, AI and ASFMRA expressed concern that the proposed form may not be the most effective approach and instead recommended complaint forms that addressed specific audiences and suggested three ways to improve the usefulness of the form:

1. The agencies should not accept complaints regarding “inaccurate” values or disagreements with the value provided by the appraiser.
2. The current section of the form entitled, “Who are you complaining about” is insufficient and should include, at a minimum, options for real estate agents and mortgage brokers.
3. Use only one classification of “appraiser.”

The letter also noted that the same suggestions apply to a form that the Consumer Financial Protection Bureau supposedly is developing separately from the Interagency Complaint Form.

Read the joint AI/ASFMRA letter.