Mar 22 -- The Appraisal Subcommittee of the Federal Financial Institutions Examination Council (ASC) invites comments by May 22, 2023 regarding a new Appraiser Profession Survey.
The importance of the appraisal industry and appraisers in the mortgage financing industry and other financial services cannot be exaggerated. Appraisals provide an objective assessment of a property's value and condition, which is essential for lending industries to mitigate risks, and for current and prospective homeowners or sellers to make informed decisions regarding moving forward with a transaction. Under section 1103 of the Financial Institutions Reform, Recovery, and Enforcement Act of 1989 (FIRREA), the ASC has the authority to monitor the requirements established by States for the certification and licensing of individuals who are qualified to perform appraisals in connection with federally related transactions, including a code of professional responsibility. In addition, under section 1106 of FIRREA the ASC has the authority to take testimony, receive evidence, provide information, and perform research, as it considers appropriate.
On June 1, 2021, President Biden launched the Property Appraisal and Valuation Equity (PAVE) Task Force, made up of 13 Federal agencies and offices, and charged with developing actions and recommendations to foster a more equitable home appraisal industry. In the PAVE Action Plan, released last year, the PAVE Task Force recognizes the barriers presented to women and communities of color in gaining access to the appraisal profession. Additionally, various studies, and other third party information from across the country indicate that there are significant barriers to entry to the appraisal profession that are negatively impacting diversity and supply in the profession.
Hence, the ASC is proposing a collection of information directly from appraisal professionals, who belong to underserved communities that historically have been denied equitable treatment due to their race or ethnicity, or both. The Appraiser Profession Survey will result in data that are needed for the ASC to better understand the challenges facing the appraisal industry today including barriers to entry into the profession and appraiser shortages. The objective is, in part, to collect new data about real estate appraisers of single-family residential properties. This data collection will improve the ASC's understanding of the current demographics of the appraisal profession, barriers to entry for aspiring appraisers, especially women and persons from underserved communities historically denied equitable treatment due to their race or ethnicity, or both, current trends and patterns of the appraisal practice, including the use of new valuation technologies and appraisal engagement practices, geographic differences in the number of appraisers in urban and rural areas; and potential market imbalances between appraiser supply and demand. These data are not available elsewhere and are essential to ASC policy development.
Data collection will focus on characteristics of appraisers that are not available in other data sources, such as the ASC's National Registry of certified and licensed appraisers. Furthermore, under federal law, certain minimum appraisal standards and appraiser qualifications are set by the Appraisal Foundation's (TAF) Appraisal Standards Board and Appraiser Qualifications Board, respectively. Accordingly, of interest to the ASC are the real world experiences of active appraisers and the potential impacts of TAF's policies and to what extent appraiser training requirements are relevant to the necessary experience needed to enter the profession. Of particular interest to the ASC is how TAF policies may disproportionately affect aspiring appraisers who historically have been denied equitable treatment because of their race or ethnicity, or both.
The survey will use online data collection and solicit responses by email and U.S. postal mail. The ASC will use appropriate statistical sampling techniques and existing datasets to draw the sample. The ASC may work with private sector providers and membership associations to identify prospective respondents to the survey. The ASC will draw a representative sample of the appraisers in the ASC Appraiser Registry and oversample appraisers that historically have been denied equitable treatment because of their race or ethnicity, or both. Based on the U.S. Bureau of Labor Statistics (BLS) reports from 2022, there are an estimated 100,000 property appraisers and assessors (appraisers cannot be separated from assessors). Of this group of 100,000 persons, approximately 7,600 are persons of color (non-white) and approximately 7,800 are persons who identify as Hispanic or Latino. Because persons who historically have been denied equitable treatment because of their race or ethnicity, or both, is a significant concern, ASC wants to include the experiences of these appraisers in the survey.
This Federal Register Notice provides an opportunity for the public to comment on the information collection for the Appraiser Profession Survey. The purpose of the survey is to learn about the experiences of appraisers, including women appraisers and appraisers from underserved communities (as defined by Executive Order 14091), and to better understand training practices and appraisal industry practices. In addition to the survey, the ASC plans to conduct in-depth interviews with several types of groups: appraisers who historically have been denied equitable treatment because of their race or ethnicity or both, women appraisers, rural appraisers, and urban appraisers living or working, or both, in historically underserved communities. The ASC wants to better understand the different experiences of urban and rural appraisers, and appraisers who historically have been denied equitable treatment because of their race, or ethnicity, or both.
Respondents: Residential real estate appraisers, both active and inactive.
Estimated Number of Respondents: 1,500
PAVE Interagency Task Force:
https://pave.hud.gov/
ASC:
https://www.asc.gov/
Draft survey and technical documentation requested from ASC by AEAStat.
FRN:
https://www.federalregister.gov/d/2023-05838