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Comment Letters

Official Comment Letters


AI Comments to ASB on the 2016-2017 USPAP, July 3, 2013

AI to the International Valuation Standards Council on Investment Property Discussion Draft, March 1, 2013

AI-ASFRMA on Proposed Interagency Appraisal Complaint Form, February 28, 2013

AI Comments to IVSC on the Exposure Draft Valuations of Specialised Public Service Assets, February 28, 2013

AI to the Guam Legislature on Disclosure of Appraisals to for Assessment Purposes, February 13, 2013

AI-ASFRMA on the Appraisal Independence Hotline, February 12, 2013

AI Comments to IVSC on the Exposure Draft Valuation Uncertainty, February 5, 2013

AI Comments to IVSC on the Exposure Draft The Valuation of Forests, January 23, 2013

AI Comments to ASB on the Third Exposure Draft of proposed changes for the 2014-15 edition of the Uniform Standards of Professional Appraisal Practice, January 17, 2013


Appraisal Institute on the Draft Policy Statements of the Appraisal Subcommittee, November 30, 2012

Consumer Group Joins Appraisal Organizations in Fee Separation Letter to CFPB, November 6, 2012

AI-ASFMRA on Proposed Rule on Higher Risk Mortgage Appraisal Requirements, October 15, 2012

AI-ASFMRA on Equal Credit Opportunity Act Appraisal Amendments, October 15, 2012

AI-ASFMRA on the Proposed Consumer Disclosure Form and Optional Disclosure of Appraisal Management Company Fees to Consumers, October 11, 2012

AI on the Draft Strategic Plan of the Appraisal Foundation, September 28, 2012

AI on the AQB Second Exposure Draft of Personal Property Appraiser Qualification Criteria, September 28, 2012

AI Comments to IVSC on the Discussion Paper Valuation of Trade Related Property, September 25, 2012

AI Comments to ASB on the Second Exposure Draft of proposed changes for the 2014-15 edition of the Uniform Standards of Professional Appraisal Practice, September 14, 2012

AI to FHFA on Property Assessed Clean Energy (PACE) Proposed Rule, September 13, 2012

Attachments to PACE letter, September 13, 2012

AI-ASFMRA on HUD Section 8 Voucher Proposal, July 16, 2012

Request for Comment: CMBS Global Property Evaluation Methodology, July 16, 2012

AI Comments to ASB on the First Exposure Draft of proposed changes for the 2014-15 edition of the Uniform Standards of Professional Appraisal Practice, June 28, 2012

Comments to the IVSC on the Exposure Draft Procedural Guidelines for Fairness Opinions, May 1, 2012

Appraisal Organizations on FHFA PACE Programs Proposed Rule, March 26, 2012

AI Comments to the Appraisal Practices Board on the 2nd Exposure Draft of Residential Appraising in a Declining Market, March 23, 2012

AI Comments to ASB on the Request for Public Comment for the 2014-15 Edition of the Uniform Standards of Professional Appraisal Practice, March 6, 2012

AI Comments to IVSC on the Exposure Draft of A Competency Framework for Professional Valuers, February 29, 2012

AI Comments to the Appraisal Practices Board on the Second Draft of Adjusting Comparable Sales for Seller Concessions, February 29, 2012

Appraisal Institute Comments on FASB Exposure Drafts on Investment Companies and Investment Property Entities, February 15, 2012

Appraisal Organizations on CFPB Proposed Consumer Disclosure Form, February 8, 2012


Letter from Appraisal Institute President Joe Magdziarz Regarding APB Exposure Drafts, December 8, 2011

AI to Appraisal Practices Board on Residential Appraising in a Declining Market, December 5, 2011

AI to the Appraisal Practices Board on Adjusting Comparable Sales for Seller Concessions, December 2, 2011

AI-ASFRMA Opposing Proposed Settlement Disclosure Form, November 16, 2011

Comments on the Discussion Draft of Communication and Reporting in the Uniform Standards of Professional Appraisal Practice (USPAP), November 15, 2011

Appraisal Organizations Response to Department of Energy’s RFI on Asset Ratings, September 22, 2011

Appraisal Organizations’ Response to FHFA’s Request for Information on REO Asset Disposition, September 15, 2011

Proposed Rule to Require Appraisers to be Certified, Rather than Licensed, for FHA Appraiser Roster, September 15, 2011

AI & ASFMRA Urge Retention of Proposed ‘Skin in the Game’ Appraisal Requirements, August 1, 2011

AI Responds to the IVSC Professional Board’s Exposure Draft of Proposed Technical Information Paper 2: Depreciated Replacement Cost, May 31, 2011

AI Responds to the International Valuation Professional Board’s Exposure Draft of Technical Paper 1: The Discounted Cash Flow (DCF) Method – Real Property and Business Valuations

AI-ASFMRA to the Consumer Financial Protection Bureau and National Association of Attorneys General

AI to the Federal Housing Finance Agency on the Uniform Appraisal Dataset

Appraisal Institute to the International Valuation Standards Board Re: Firm Certifications, April 18, 2011

Comments on the Fifth Exposure Draft of Proposed Changes for the 2012-13 edition of the Uniform Standards of Professional Appraisal Practice, April 1, 2011

AI on the Proposed International Valuation Standards, March 25, 2011

AI-ASFMRA to House of Representatives on H.R. 567 and DoL Fiduciary Responsibility Proposal, March 3, 2011

AI Joins Real Estate Trade Groups in Opposing DOL Fiduciary Responsibility Proposal, February 2, 2011

Comments to the Appraisal Standards Board on the Fourth Exposure Draft of proposed changes for the 2012-13 edition of the Uniform Standards of Professional Appraisal Practice, January 14, 2011

Appraisal Institute Responds to Department of Labor’s Proposal to Define Appraisers as a Fiduciary Under ERISA, January 5, 2011


Appraisal Institute Responds to Fed Interim Final Rule Addressing Appraiser Independence and Customary and Reasonable Fees to Appraisers, December 27, 2010

Appraisal Institute Calls for Development of Investment Property Accounting Standard, December 15, 2010

AI Responds to the AQB’s First Exposure Draft of Proposed Revisions to the Future Real Property Appraiser Qualification Criteria Dated October 19, 2010, November 24, 2010

AI-ASFMRA on SEC Asset Backed Securities Proposal, November 16, 2010

Comments to the Appraisal Standards Board on the Third Exposure Draft of proposed changes for the 2012-13 edition of the Uniform Standards of Professional Appraisal Practice, November 12, 2010

Comments to the International Valuation Professional Board on the Discussion Paper Definition of a Professional Valuer, September 30, 2010

Comments to the International Valuation Professional Board on the Exposure Draft Proposed Code of Ethics for Professional Valuers, September 30, 2010

Appraisal Organizations Comment to the Federal Reserve on TILA, Customary and Reasonable Fees, September 23, 2010

Comments to the International Valuation Standards Council on the Exposure Draft Proposed New International Valuation Standards, September 3, 2010

Casey Appraisal Amendment to S. 3217, the Restoring American Financial Security Act, May 13, 2010

Appraisal Organizations Urge State Boards to Look at Broker Opinions of Value, April 20, 2010

Appraisal Organizations Seek Clarification from HUD on New RESPA Rule FAQs, April 8, 2010

Appraisal Organizations Submit Follow-up Letter on HAFA, March 24, 2010

Appraisal Organizations Respond to Nevada’s Allowance of a BPO in Foreclosure Mediation Program, March 12, 2010

Appraisal Organizations Voice Concerns Regarding HAFA Program and Notably the Short Sales Component, March 8, 2010

Appraisal Standards Committee Comments to the Appraisal Standards Board on the First Exposure Draft of Proposed Changes to the 2012-2013 Edition of USPAP, February 1, 2010

Appraisal Institute Comments on TAF Financial Reporting Discussion Questions, January 20, 2010

AI-ASA-ASFMRA-NAIFA to the Federal Reserve Board regarding Commercial Broker Price Opinions, January 19, 2010

Letter of Response: Federal Reserve Staff Position, January 19, 2010

Appraisal Organizations call on Interior Department to Implement Inspector General’s Recommendations, January 7, 2010


AI Calls on Federal Reserve to Suspend HELOC Rulemaking, December 23, 2009

AI-ASA-ASFMRA-NAIFA to House Appropriations Committee in Support of Appraisal Services Directorate, November 24, 2009

Appraisal Organizations Urge Senate not to Raise SBA’s Appraisal Threshold, November 23, 2009

Appraisal Organizations Call for Congress to Extend Tax Deduction for Charitable Contributions, November 2, 2009

Appraisal Organizations Submit Testimony Clarifying Appraisal Methods and Techniques, October 14, 2009

Appraisal Organizations call on the Federal Housing Administration to enhance appraiser independence and to more closely monitor mortgage brokers and appraisal management companies, September 16, 2009

AI-ASA-ASFMRA-NAIFA to HUD on Appraisal Management Company Fees, July 1, 2009

Appraisal Organizations Voice Concerns Regarding H.R. 2336, the GREEN Act of 2009, June 23, 2009

Appraisal Institute Comments on The Identification of Contributory Assets and the Calculation of Economic Rents Exposure Draft, April 30, 2009

Appraisal Organizations Respond to Treasury Department’s Making Home Affordable Program, March 11, 2009

Appraisal Organizations Write to Treasury Secretary Urging that Qualified Appraisers Value Homes Under President’s Obama’s Homeowners Stability Program, February 19, 2009

Appraisal Organizations Join Real Estate Trade Organizations in Support of Commercial Real Estate Credit Access, February 10, 2009

Appraisal Organizations write to the Federal Reserve calling for appraisals in their Homeownership Preservation Policy for Residential Mortgage Assets program, February 4, 2009

AI to Federal Bank Regulatory Agencies on Proposed Interagency Appraisal and Evaluation Guidelines, January 20, 2009


Industry Sends Letter to FDIC on Loan Modifications, November 19, 2008

AI-ASFMRA letter to the Securities and Exchange Commission regarding Financial Accounting Statement 157, November 7, 2008

Appraisal Institute’s letter to IRS Supporting Proposed Rule on the Substantiation and Reporting Requirements for Cash and Noncash Charitable Contribution Deductions, November 5, 2008

Appraisal Management Company Model Legislation, November 3, 2008

Industry Letter to Senate Regarding Emergency Economic Stabilization Act of 2008, H.R.1424, October 1, 2008

AI-ASA-ASFMRA-NAIFA Comment Letter to FHA Commissioner Regarding H.R. 3221, the Housing and Economic Recovery Act, September 26, 2008

AI-ASA-ASFMRA-NAIFA Comment Letter on Proposed Troubled Asset Relief Program (TARP), September 24, 2008

AI-ASA-ASFMRA-NAIFA Letter to the American Securitization Forum on Residential Securitization Transparency and Reporting (Project RESTART), September 22, 2008

AI-NAIFA Comment Letter on The Appraisal Foundation’s Strategic Goals, September 2, 2008

Appraisal Institute Sends Letter to Senate Banking Committee in Response to Associate Press’ August 18 Title XI Article, August 19, 2008

Appraisal Institute Encourages SEC to Work with Valuation Community to Implement Financial Reporting Improvements, July 22, 2008

Appraisal Institute Applauds Federal Reserve’s Action Against Appraiser Coercion by Creditors, Mortgage Brokers, July 22, 2008

Appraisal Institute to HUD regarding recent policy communique’s effect in Puerto Rico, July 8, 2008

Puerto Rico and Carribbean Chapter’s Letter to the Appraisal Institute regarding HUD policies, June 17, 2008

Appraisal Institute to HUD on the proposed rule on the Real Estate Settlement Procedures Act, June 12, 2008

Appraisal Institute to Sens. Casey and Martinez on appraisal reforms to foreclosure prevention legislation, May 13, 2008

Appraisal Institute to IRS on Modifications of Commercial Mortgage Loans Held by REMICs, March 27, 2008

AI-ASA-ASFMRA-NAIFA Letter to Fed on Regulation Z, March 17, 2008


AI-ASA-ASFMRA-NAIFA to the Government Accounting Standards Board , June 29, 2007

Appraisal Institute supports fair value standard for public endowments, encourages use of appraisals

AI-ASA-ASFMRA-NAIFA Letter to Chairman Ben S. Bernanke, June 14, 2007

AI-ASA-ASFMRA-NAIFA to Chairmen of House and Senate banking committees , June 13, 2007

Appraisal groups express concerns over Annual Report of the Appraisal Subcommittee, appraiser regulatory structure

AI-ASA-ASFMRA-NAIFA to The Honorable Geoff Davis, April 19, 2007

Appraisal groups support Promoting Transparency in Financial Reporting

AI-ASA-ASFMRA-NAIFA to State Appraisal Boards , April 18, 2007

Appraisal groups ask state boards to reconsider requiring AQB approval for Continuing Education Courses.

AI-ASA-ASFMRA-NAIFA to Federal Bank Regulatory Agencies , April 11, 2007

Appraisal call for reemphasis of collateral issues with regard to Subprime Mortgage Lending

AI-ASA-ASFMRA-NAIFA to Sens. Baucus and Grassley , April 3, 2007

Appraisal groups support permanent extension of conservation easement tax incentives

AI-ASA-ASFMRA-NAIFA to Members of the Senate Banking and House Financial Services Committee , February 6, 2007

Appraisal groups call for mortgage fraud, appraisal regulatory reforms
Attachment 1: Appraisal Reform Objectives
Attachment 2: National Appraisal Survey Executive Summary

AI-ASFMRA-NAIFA on Transitional Guidance on Appraisal Requirements for Noncash Charitable Contributions, January 17, 2007

Appraisal groups support new definition of “qualified appraiser”, call for open and fair process for disciplining appraisers

Pension Protection Act Discussion: Impact on Real Estate Appraisers, January 16, 2007

Don Kelly, Chief External Relations Officer, discusses the impact of IRS appraisal reforms on appraisers


Comments on Consultation on Improvements to GN 8 – The Cost Approach for Financial Reporting, AI to IVSC, December 21, 2006

Attachment to Comments on Consultation on Improvements to GN 8 – The Cost Approach for Financial Reporting, AI to IVSC, December 21, 2006

Comments on Proposed Statement on Standards for Valuation Services – Valuation of a Business, Business Ownership Interest, Security, or Intangible Asset, AI to AICPA, December 15, 2006

Appraisal Organization Urge Enactment of Appraisal, Mortgage Fraud Reforms, November 29, 2006

AI-ASA-ASFMRA to Rep. Barney Frank and Sen. Christopher Dodd

AI-ASA-ASFMRA on NRCS’s Farm and Ranchlands Program, August 31, 2006

Appraisal organizations comment on appraisal policies found in the Natural Resource and Conservations Service’s Interim Rule on the revamped Farm and Ranchlands Program.

AI-ASA-ASFMRA on Passage of Pension Protection Act, H.R. 4

Groups thank Ways and Means and Finance Committee Members for their support of IRS appraisal reforms

AI-ASA-ASFMRA on BLM’s Proposed Rule on Linear Rights of Way, July 27, 2006

Appraisal groups provide comment on new fee schedules proposed by Bureau of Land Management

AI-ASA-ASFMRA to Members of the U.S. House Ways and Means Committee July 25, 2006

The three organizations urge members of Congress to include charity reforms provisions (which include IRS-related appraisal reforms) with the Pension Bill conference report (HR 2830).

AI-ASA-ASFMRA to Federal Banking Regulators on Scope of Work, July 24, 2006

The three organizations comment on the Banking Regulators’ recent revisions to USPAP.

AI-ASA-ASFMRA to HUD on Its Anti-Flipping Rule, July 7, 2006

Appraisal Groups clarify the role of appraisers in mortgage, refinance and equity lending
HUD Response August 10, 2006

Appraisal Institute to Canadian Accounting Standards Board on Measurement Basis for Initial Recognition, May 19, 2006

AI-ASA-ASFMRA on Indian Rights-of-Way, May 12, 2006

Appraisal organizations support market value for right-of-way valuation

AI-ASA-ASFMRA to the Banking Regulators on Concentrations in Commercial Real Estate, April 13, 2006

Appraisal groups make recommendations regarding banks’ market analysis practices

AI-ASA-ASFMRA on Nontraditional Mortgage Loan Products, March 29, 2006

Appraisal groups support guidance and call for action on mortgage lenders/brokers and appraisal reviews

AI-ASA-ASFMRA to Senator Barack Obama, February 22, 2006

Appraisal groups comend Senator Obama for introduction of the STOP FRAUD Act of 2006 (S. 2280)

Appraisal Institute and Others In Support of IRS Appraisal Reforms, February 15, 2006

Appraisal groups urge conferees to support Senate-passed version of H.R. 4297

AI-ASA-ASFMRA to Members of House Financial Services Committee , February 10, 2006

Appraisal groups call for enactment of appraisal reforms in H.R. 1295, Responsible Lending Act

AI-ASA-ASFMRA to FBI, IRS, HUD, USDOJ and USPS, January 5, 2006

Appraisal Groups Commend “Operation Quick Flip,” Commit to Combatting Mortgage Fraud


Appraisal Institute to FASB on revision of Business Combinations (FAS 141), October 26, 2005

AI-ASA-ASFMRA on Threatened and Endangered Species Act (H.R. 3824), October 24, 2005

Appraisal organizations suggest bill should incorporate highest and best use and GAVP

AI-ASA-ASFMRA on Conservation Easement Valuation, June 7, 2005

Appraisal groups write to all members of Senate Finance Committee in advance of Hearing Attachment

AI-ASA-ASFMRA-NAIFA to the Independent Sector on Easement Valuations, May 19, 2005

Appraisal groups provide comment on IS recommendations to Senate Finance Committee
AI and appraisal organizations to Members of Senate Finance Committee, April 15, 2005

Appraisal organization reiterate concerns about the valuation of conservation/preservation easements
AI-ASA-ASFMRA Commend Reps. Bob Ney and Paul Kanjorski on Responsible Lending Act, March 16, 2005

Groups support appraisal provisions of H.R. 1295
AI-ASA-ASFMRA to Senate Finance and House Ways and Means Committees, February 9, 2005

Appraisal groups call for modifications to tax laws on conservation and historic preservation
AI-ASA-ASFMRA to Department of Interior Secretary Gale Norton, January 24, 2005

Appraisal groups commend Department on internal appraisal reforms, new appraisal policies

AI-ASA-ASFMRA to the Environmental Protection Agency on Brownfields Law, November 11, 2004

Appraisal Groups Seek Clarification of “All Appropriate Inquiry” Proposed Rule
AI-ASA-ASFMRA to the Veterans Administration Regarding Recruitment, November 1, 2004

Appraisal groups encourage recognition of appraiser designations
AI to the Small Business Administration Regarding SBA Appraisal Requirements, September 17, 2004

Organization urges revision of SBA SOP 50-10 regarding going concern value and SOP inconsistencies AI Recommended Changes to SOP 50-10 Appraisal Requirements
AI to FASB on Fair Value Measurements, September 7, 2004

Appraisal Institute urges recognition of generally accepted valuation principles.
AI to CFA Institute on ‘Gold’ Global Investment Performance Standards (GIPS), August 31, 2004

Appraisal Institute offers feedback on propsed real estate provisions of international investment performance standards.
AI-ASA-ASFMRA to the SEC on Public Company Accounting Oversight Board Audit Standards, August 10, 2004

Appraisal groups support recognition of appraisers as specialists, increased due diligence by auditors
AI-ASA-ASFMRA to Senate Finance Committee, May 24, 2004

Appraisal groups provide feedback on the valuation of conservation easements
AI, ASFMRA, ASA Urge AARO to Encourage Streamlining of Education Approval Process, April 21, 2004

Association of Appraisar Regulatory Officials
AI-ASFMRA to the International Valuation Standards Committee, March 31, 2004

Appraisal organizations respond to Guidance Note for Mass Appraisal for Property Taxation
AI-ASA-ASFMRA to the International Valuation Standards Committee, March 18, 2004

Appraisal groups respond to position statement on valuation of assets for financial statements
AI-ASA-ASFMRA-NAR to the Federal Highway Administration, February 17, 2004

Appraisal Groups Respond to Proposed Changes to the “Uniform Act”
AI-ASA-ASFMRA to Rep. Donald Manzullo on HUD’s RESPA Scheme, January 8, 2004

Appraisal groups call for legislation overturning HUD’s RESPA “runaway train”

AI-ASA-ASFMRA to the Public Company Accounting Oversight Board, December 17, 2003

Appraisal organizations support the candidacies of two appraisers to a PCAOB advisory board
AI-ASA-ASFMRA on H.R. 3261, The Database and Collections of Information Misappropriation Act, December 8, 2003

Appraisal groups oppose legislation that would privatize public information
AI-ASA-ASFMRA on H.R. 3322, the Save Our Homes Act of 2003, November 7, 2003

Letter thanking Rep. Janice Schakowsky for continued efforts addressing appraiser coercion
Major real estate groups express support for H.R. 2896, the American Jobs Creation Act of 2003, November 4, 2003

Letter sent to all members of the U.S. House of Representatives
AI-ASA-ASFMRA to Senator Conrad Burns and Senator Byron Dorgan, October 30, 2003

Appraisal Groups Support Department of Interior Appraisal Reforms
AI-ASA-ASFMRA to the International Valuations Standards Committee, October 29, 2003

Comment letter on IVSC Consultative Paper on Valuation of Owner-Occupied Properties
AI-ASFMRA-NAR to the Internal Revenue Service, October 24, 2003

Comments on the Draft IRS Real Property Valuation Guidelines
AI Letter to the Editor of the Grand Forks Herald, October 24, 2003

Letter regarding Department of Interior Appraisal Reforms
AI on the Implementation of the Cabin User Fee Fairness Act of 2000, August 11, 2003

Official comments to the U.S. Forest Service on Proposed Rule
AI Joins Coalition In Support of The American Jobs Creation Act of 2003, July 25, 2003

Groups Express Support for Permanent 20 Year Depreciable Life for Leasehold Improvements
AI-ASA-IAAO to the Public Company Accounting Oversight Board, July 24, 2003

Valuation organizations recommend the appointment of an appraiser to a PCAOB Advisory Board
AI-NAR in Support of Abandoned Mine Land Area Redevelopment Act of 2003, July 23, 2003

Groups support tax incentives to assist redevelopment of abandoned coal mines
AI-ASA on H.R. 2043, the U.S. Financial Policy Committee Fair Capital Standards Act, June 17, 2003

Groups call on Congress to allow impacted industries to participate in U.S. policymaking on Basel Accords
AI-ASA on Potential Money Laundering Regulations from the Treasury Department, June 9, 2003

Groups state appraisers in no position to identify money laundering activities
AI Letter to the Editor of the Wall Street Journal, June 2, 2003

AI responds to a recent article describing HUD’s RESPA reform proposal
AI-ASA-NAR-ASFMRA on the effectiveness of the Appraiser Regulatory Structure, May 20, 2003

Letter to Reps. Oxley, Frank and Sens. Shelby and Sarbanes on the recently released GAO report
AI-ASA letter on H.R. 1500, the Veterans’ Appraiser Choice Act, April 24, 2003

Letter to Rep. Adam Smith (D-WA) requesting reconsideration and withdrawal H.R. 1500
AI-ASA on Section 614 of H.R. 1375, the Financial Services Regulatory Relief Act, April 8, 2003

Letter to Rep. Spencer Bachus (R-AL) and Rep. Bernie Sanders (I-VT) in opposition to increased liability
AI-ASA on HUD Proposed Rule on Lender Accountability for Appraisals, March 14, 2003

Comment Letter to HUD in support of holding lenders equally accountable for appraisals
AI-ASA-NAR on Appraisal Regulatory Structure, January 24, 2003

Letter to Sen. Richard Shelby, R-AL, detailing deficiencies in the appraisal regulatory structure

AI on HUD Strategic Plan, December 13, 2002

Letter to Secretary Mel Martinez on HUD’s long-term strategic goals
AI-ASA on Third AQB Exposure Draft, December 3, 2002

Letter to the Appraisal Qualifications Board on its 3rd Exposure Draft on appraiser qualifications
AI-ASA on Privacy Exemption for Real Estate Appraisers, November 18, 2002

Letter to Rep. Judy Biggert, R-IL, on recent privacy law’s impact on real estate appraisers
AI-ASA on HUD RESPA Proposal, October 29, 2002

Letter to HUD detailing concerns about HUD RESPA reform proposal
AI-ASA on Going Concern Value, October 23, 2002

Letter to Small Business Administration expressing concerns on appraisal policies and lending against going concern values
AI-ASA-NAR on HUD Appraiser Watch Initiative, September 18, 2002

Letter to HUD commenting on HUD’s proposal to use the default rate as a primary measure of the work of real estate appraisers
AI on Appraiser Qualifications for Placement on the FHA Single Family Appraiser Roster, January 29, 2002

Letter to HUD commenting on HUD’s inability to remove unqualified appraisers from the FHA Appraiser Roster

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