Letters & Testimony
Congressional Testimony
AI President Sara Stevens Testifies in front of the House Financial Services Subcommitte on Insurance, Housing and Community Opportunity (video), June 28, 2012
AI-ASFMRA Written Testimony to the House Financial Services Subcommitte on Insurance, Housing and Community Opportunity, June 28, 2012
AI-ASFMRA on Mortgage Disclosures and Separation of Appraisal and AMC Fees, June 20, 2012
AI-ASFMRA Testimony Before the House Financial Services on High Voltage Transmission Towers, April 14, 2012
AI-ASFRMA to the U.S. Sentencing Commission on Mortgage Fraud Sentencing Calculations, March 14, 2012
AI-ASFMRA Statement for Record on H.R. 3461 Financial Institutions Examination Fairness and Reform Act, February 1, 2012
AI Before the House Financial Services Subcommittee on Investigations on
Mortgage Origination Issues, July 13, 2011:
Written Testimony for House Financial Services Subcommittee on Commercial
Real Estate, May 17, 2010
Oral Testimony for House Financial Services Subcommittee on Commercial
Real Estate, May 17, 2010
Appraisal Institute Testifies Before the House Financial Services
Committee on H.R. 1728, the Mortgage Reform and Anti-Predatory Lending Act of 2009,
April 23, 2009
Appraisal Institute Testifies Before the House Committee on Financial
Services' Subcommittee on Financial Institutions and Consumer Credit at the Subcommittee's
Mortgage Lending Reform Hearing, March 11, 2009
Appraisal Institute Testifies in IRS Public Hearing on Reporting Requirements for
Cash and Noncash Charitable Contributions, January 23, 2009
Appraisal Institute and partners testify before the Senate Subcommittee on Housing,
Transportation, and Community Opportunity, June 26, 2007
AI-ASA-ASFMRA Testify Before the House Committee on Financial Services,
May 24, 2005
AI-ASA-ASFMRA on International Convergence of Accounting Standards and Financial
Reporting Requirements, September 24, 2004
AI-ASA-ASFMRA Before the House Financial Services Committee,
June 14, 2004
AI-ASFMRA Before the Senate Committee on Banking, Housing and Urban Affairs,
March 24, 2004
AI-ASA
Before the House Committee on Veterans' Affairs on Veterans' Appraiser Choice Act,
June 11, 2003
AI-ASA on the Reauthorization of the Small Business Administration, May
15, 2003
AI-ASA
on RESPA Reform's impact on small business, March 11, 2003
AI-ASA
on RESPA Reform's impact on real estate appraisers, February 25, 2003
AI on Leaking Underground Storage Tanks, September 12, 2002
AI on
Appraiser Involvement in Mortgage Fraud, July 27, 2001
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Official Comment Letters
2013
AI-ASFRMA on Proposed Interagency Appraisal Complaint Form, February 28, 2013
AI to the International Valuation Standards Council on Investment Property Discussion Draft, March 1, 2013
AI Comments to IVSC on the Exposure Draft Valuations of Specialised Public Service Assets, February 28, 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
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2012
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
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2011
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 RatingsSeptember 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
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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
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2010
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
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2009
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
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2008
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
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2007
AI-ASA-ASFMRA-NAIFA to the Government Accounting Standards Board, June 29,
2007
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
AI-ASA-ASFMRA-NAIFA to The Honorable Geoff Davis, April
19, 2007
AI-ASA-ASFMRA-NAIFA
to State Appraisal Boards, April 18, 2007
AI-ASA-ASFMRA-NAIFA to Federal Bank Regulatory Agencies, April 11, 2007
AI-ASA-ASFMRA-NAIFA
to Sens. Baucus and Grassley, April 3, 2007
AI-ASA-ASFMRA-NAIFA
to Members of the Senate Banking and House Financial Services Committee,
February 6, 2007
AI-ASFMRA-NAIFA on Transitional Guidance on Appraisal Requirements
for Noncash Charitable Contributions, January 17, 2007
Pension Protection Act Discussion: Impact on Real Estate Appraisers, January
16, 2007
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2006
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 on NRCS's Farm and Ranchlands Program, August
31, 2006
AI-ASA-ASFMRA on Passage of Pension Protection Act, H.R. 4
AI-ASA-ASFMRA on BLM's Proposed Rule on Linear Rights of Way,
July 27, 2006
AI-ASA-ASFMRA to Members of the U.S. House Ways and Means Committee, July
25, 2006
AI-ASA-ASFMRA to Federal Banking Regulators on Scope of Work, July 24, 2006
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
AI-ASA-ASFMRA to the Banking Regulators on Concentrations in Commercial Real Estate,
April 13, 2006
AI-ASA-ASFMRA on Nontraditional Mortgage Loan Products,
March 29, 2006
AI-ASA-ASFMRA to Senator Barack Obama, February 22, 2006
Appraisal Institute and Others In Support of IRS Appraisal Reforms, February
15, 2006
AI-ASA-ASFMRA to Members of House Financial Services Committee, February
10, 2006
AI-ASA-ASFMRA to FBI, IRS, HUD, USDOJ and USPS, January
5, 2006
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2005
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
AI-ASA-ASFMRA on Conservation Easement Valuation, June 7,
2005
AI-ASA-ASFMRA-NAIFA to the Independent Sector on Easement Valuations, May
19, 2005
AI and appraisal organizations to Members of Senate Finance Committee, April
15, 2005
AI-ASA-ASFMRA Commend Reps. Bob Ney and Paul Kanjorski on Responsible Lending Act,
March 16, 2005
AI-ASA-ASFMRA to Senate Finance and House Ways and Means Committees, February
9, 2005
AI-ASA-ASFMRA to Department of Interior Secretary Gale Norton, January 24,
2005
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2004
AI-ASA-ASFMRA to the Environmental Protection Agency on "Brownfields Law",
November 11, 2004
AI-ASA-ASFMRA to the Veterans Administration Regarding Recruitment, November
1, 2004
AI to the Small Business Administration Regarding SBA Appraisal Requirements,
September 17, 2004
AI to FASB on Fair Value Measurements, September 7, 2004
AI to CFA Institute on 'Gold' Global Investment Performance Standards (GIPS),
August 31, 2004
AI-ASA-ASFMRA to the SEC on Public Company Accounting Oversight
Board Audit Standards, August 10, 2004
AI-ASA-ASFMRA to Senate Finance Committee, May 24, 2004
AI, ASFMRA, ASA Urge AARO to Encourage Streamlining of Education Approval Process,
April 21, 2004
AI-ASFMRA to the International Valuation Standards Committee, March 31,
2004
AI-ASA-ASFMRA to the International Valuation Standards Committee, March
18, 2004
AI-ASA-ASFMRA-NAR to the Federal Highway Administration, February 17, 2004
AI-ASA-ASFMRA to Rep. Donald Manzullo on HUD's RESPA Scheme, January 8,
2004
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2003
AI-ASA-ASFMRA to the Public Company Accounting Oversight Board, December
17, 2003
AI-ASA-ASFMRA on H.R. 3261, The Database and Collections of Information Misappropriation
Act, December 8, 2003
AI-ASA-ASFMRA on H.R. 3322, the Save Our Homes Act of 2003, November 7,
2003
Major real estate groups express support for H.R. 2896, the American
Jobs Creation Act of 2003, November 4, 2003
AI-ASA-ASFMRA to Senator Conrad Burns and Senator Byron Dorgan, October
30, 2003
AI-ASA-ASFMRA to the International Valuations Standards Committee, October
29, 2003
AI-ASFMRA-NAR to the Internal Revenue Service, October 24,
2003
AI
Letter to the Editor of the Grand Forks Herald, October 24, 2003
AI on the Implementation of the Cabin User Fee Fairness Act of 2000, August
11, 2003
AI Joins Coalition In Support of The American Jobs Creation Act of 2003,
July 25, 2003
AI-ASA-IAAO to the Public Company Accounting Oversight Board, July 24, 2003
AI-NAR
in Support of Abandoned Mine Land Area Redevelopment Act of 2003, July 23,
2003
AI-ASA on H.R. 2043, the U.S. Financial Policy Committee Fair Capital Standards
Act, June 17, 2003
AI-ASA
on Potential Money Laundering Regulations from the Treasury Department,
June 9, 2003
AI Letter
to the Editor of the Wall Street Journal, June 2, 2003
AI-ASA-NAR-ASFMRA on the effectiveness of the Appraiser Regulatory Structure,
May 20, 2003
AI-ASA letter on H.R. 1500, the Veterans' Appraiser Choice Act, April 24,
2003
AI-ASA on Section 614 of H.R. 1375, the Financial Services Regulatory Relief Act,
April 8, 2003
AI-ASA on HUD Proposed Rule on Lender Accountability for Appraisals, March
14, 2003
AI-ASA-NAR on Appraisal Regulatory Structure, January 24, 2003
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2002
AI on HUD Strategic Plan, December 13, 2002
AI-ASA
on Third AQB Exposure Draft, December 3, 2002
AI-ASA on Privacy Exemption for Real Estate Appraisers, November 18, 2002
AI-ASA on HUD RESPA Proposal, October 29, 2002
AI-ASA on Going Concern Value, October 23, 2002
AI-ASA-NAR on HUD Appraiser Watch Initiative, September
18, 2002
AI on Appraiser Qualifications for Placement on the FHA Single Family Appraiser
Roster, January 29, 2002
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Pending Amendments
NEW!
Highlights of H.R. 1728 Appraisal Provisions, May 12, 2009
Mortgage Reform and Anti-Predatory Lending Act of 2009 (Version Passed by House
Financial Services Committee), May 7, 2009
H.R.
1728 Amendment Proposed by Financial Services Committee Chairman Barney Frank,
May 7, 2009
H.R. 1728 Amendment Proposed by Congressman Paul Kanjorski,
April 28, 2009
Congressman Kanjorski will offer this amendment during the markup of H.R. 1728.
The comprehensive amendment makes changes
to titles V and VI of the bill concerning escrows, mortgage servicing and appraisals.
Explanation of Kanjorski Amendment to H.R. 1728, April 28,
2009
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