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Letters & Testimony
Congressional Testimony - View All 
Official Comments - View All
Congressional Testimony
- Appraisal Institute and partners
testify before the Senate Subcommittee on Housing, Transportation, and Community
Opportunity, June 26, 2007
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Appraisal organizations express support for Congressional action on appraiser coercion,
mortgage fraud, and appraisal reform
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Oral Testimony - Alan E. Hummel,
SRA
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AI-ASA-ASFMRA Testify Before
the House Committee on Financial Services, May 24, 2005
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Appraisal groups testify in support of proposed appraisal reforms (H.R. 1295, Responsible
Lending Act)
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Oral Testimony - Alan E. Hummel, SRA
- AI-ASA-ASFMRA on International
Convergence of Accounting Standards and Financial Reporting Requirements,
September 24, 2004
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Appraisal groups present testimony before the Senate Committee on Banking, Housing
and Urban Affairs
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AI-ASA-ASFMRA Before the House
Financial Services Committee, June 14, 2004
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Appraisal groups discuss mortgage fraud in The Poconos and call for reform of FIRREA
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Oral Testimony - Gary P. Taylor,
MAI, SRA
- AI-ASFMRA Before the Senate
Committee on Banking, Housing and Urban Affairs, March 24, 2004
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Appraisal groups say FIRREA gets a failing grade; suggest legislative changes
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Oral Testimony - Alan E. Hummel
- AI-ASA Before the House Committee on Veterans' Affairs
on Veterans' Appraiser Choice Act, June 11, 2003
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Appraisal Groups: VA Program can be improved without jeopardizing appraiser independence
- AI-ASA on the Reauthorization of the Small Business
Administration, May 15, 2003
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Alan Hummel, SRA testifies before the Senate Committee on Small Business
- AI-ASA on RESPA Reform’s impact on small business,
March 11, 2003
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Alan Hummel, SRA testifies before the House Small Business Committee
- AI-ASA on RESPA Reform’s impact on real estate appraisers,
February 25, 2003
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Alan Hummel, SRA testifies before the House Financial Services Committee on RESPA
reform
- AI on Leaking Underground Storage Tanks,
September 12, 2002
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William C. Harvey, MAI testifies before the House Financial Services Committee on
detrimental conditions
- AI on Appraiser Involvement in Mortgage Fraud,
July 27, 2001
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Brian Glanville, MAI testifies before the Senate Banking Committee on appraiser
involvement in mortgage fraud
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Official Comments
- 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
- 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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AI-ASA-ASFMRA-NAIFA to the
Government Accounting Standards Board, June 29, 2007
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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
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Appraisal groups express concerns over Annual Report of
the Appraisal Subcommittee, appraiser regulatory structure
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AI-ASA-ASFMRA-NAIFA to The
Honorable Geoff Davis, April 19, 2007
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Appraisal groups support Promoting Transparency in Financial
Reporting
- AI-ASA-ASFMRA-NAIFA to State
Appraisal Boards, April 18, 2007
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Appraisal groups ask state boards to reconsider requiring
AQB approval for Continuing Education Courses.
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AI-ASA-ASFMRA-NAIFA to Federal
Bank Regulatory Agencies, April 11, 2007
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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
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Appraisal groups support permanent extension of conservation
easement tax incentives
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AI-ASA-ASFMRA-NAIFA to Members
of the Senate Banking and House Financial Services Committee, February
6, 2007
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Appraisal groups call for mortgage fraud, appraisal regulatory
reforms
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Attachment 1:
Appraisal Reform Objectives
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Attachment 2:
National Appraisal Survey Executive
Summary
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AI-ASFMRA-NAIFA on Transitional
Guidance on Appraisal Requirements for Noncash Charitable Contributions,
January 17, 2007
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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
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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
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AI-ASA-ASFMRA to
Rep. Barney Frank
and Sen. Christopher Dodd
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AI-ASA-ASFMRA on NRCS's Farm
and Ranchlands Program, August 31, 2006
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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
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Groups thank Ways and Means and Finance Committee Members
for their support of IRS appraisal reforms
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AI-ASA-ASFMRA on BLM's Proposed
Rule on Linear Rights of Way, July 27, 2006
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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
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The three organizations comment on the Banking Regulators'
recent revisions to USPAP.
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AI-ASA-ASFMRA to HUD on Its
Anti-Flipping Rule, July 7, 2006
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Appraisal Groups clarify the role of appraisers in mortgage,
refinance and equity lending
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HUD Response, August 10, 2006
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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
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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
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Appraisal groups make recommendations regarding banks' market
analysis practices
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AI-ASA-ASFMRA on Nontraditional
Mortgage Loan Products, March 29, 2006
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Appraisal groups support guidance and call for action on
mortgage lenders/brokers and appraisal reviews
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AI-ASA-ASFMRA to Senator Barack
Obama, February 22, 2006
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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
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Appraisal groups urge conferees to support Senate-passed
version of H.R. 4297
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AI-ASA-ASFMRA to Members of
House Financial Services Committee, February 10, 2006
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Appraisal groups call for enactment of appraisal reforms in H.R. 1295, Responsible
Lending Act
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AI-ASA-ASFMRA to FBI, IRS,
HUD, USDOJ and USPS, January 5, 2006
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Appraisal Groups Commend "Operation Quick Flip," Commit to Combatting Mortgage Fraud
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Appraisal Institute to FASB
on revision of Business Combinations (FAS 141), October 26, 2005
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AI-ASA-ASFMRA on Threatened
and Endangered Species Act (H.R. 3824), October 24, 2005
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Appraisal organizations suggest bill should incorporate highest and best use and
GAVP
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AI-ASA-ASFMRA on Conservation
Easement Valuation, June 7, 2005
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Appraisal groups write to all members of Senate Finance Committee in advance of
Hearing
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Attachment
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AI-ASA-ASFMRA-NAIFA to the
Independent Sector on Easement Valuations, May 19, 2005
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Appraisal groups provide comment on IS recommendations to Senate Finance Committee
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AI and appraisal organizations
to Members of Senate Finance Committee, April 15, 2005
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Appraisal organization reiterate concerns about the valuation of conservation/preservation
easements
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AI-ASA-ASFMRA Commend Reps.
Bob Ney and Paul Kanjorski on Responsible Lending Act, March 16,
2005
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Groups support appraisal provisions of H.R. 1295
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AI-ASA-ASFMRA to Senate Finance
and House Ways and Means Committees, February 9, 2005
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Appraisal groups call for modifications to tax laws on conservation and historic
preservation
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AI-ASA-ASFMRA to Department
of Interior Secretary Gale Norton, January 24, 2005
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Appraisal groups commend Department on internal appraisal reforms, new appraisal
policies
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AI-ASA-ASFMRA to the Environmental
Protection Agency on "Brownfields Law", November 11, 2004
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Appraisal Groups Seek Clarification of "All Appropriate Inquiry" Proposed Rule
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AI-ASA-ASFMRA to the Veterans
Administration Regarding Recruitment, November 1, 2004
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Appraisal groups encourage recognition of appraiser designations
- AI to the Small Business Administration Regarding SBA
Appraisal Requirements, September 17, 2004
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Organization urges revision of SBA SOP 50-10 regarding going concern value and SOP
inconsistencies
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AI Recommended Changes to SOP 50-10 Appraisal Requirements
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AI to FASB on Fair Value Measurements,
September 7, 2004
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Appraisal Institute urges recognition of generally accepted valuation principles.
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AI to CFA Institute on 'Gold'
Global Investment Performance Standards (GIPS), August 31, 2004
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Appraisal Institute offers feedback on propsed real estate provisions of international
investment performance standards.
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AI-ASA-ASFMRA to the SEC on
Public Company Accounting Oversight Board Audit Standards, August
10, 2004
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Appraisal groups support recognition of appraisers as specialists, increased due
diligence by auditors
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AI-ASA-ASFMRA to Senate Finance
Committee, May 24, 2004
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Appraisal groups provide feedback on the valuation of conservation easements
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AI, ASFMRA, ASA Urge AARO to
Encourage Streamlining of Education Approval Process, April 21, 2004
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Association of Appraisar Regulatory Officials
- AI-ASFMRA to the International
Valuation Standards Committee, March 31, 2004
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Appraisal organizations respond to Guidance Note for Mass Appraisal for Property
Taxation
- AI-ASA-ASFMRA to the International
Valuation Standards Committee, March 18, 2004
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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
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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
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Appraisal groups call for legislation overturning HUD's RESPA "runaway train"
- AI-ASA-ASFMRA to the Public Company
Accounting Oversight Board, December 17, 2003
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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
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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
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Letter thanking Rep. Janice Schakowsky for continued efforts addressing appraiser
coercion
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Major real estate groups express
support for H.R. 2896, the American Jobs Creation Act of 2003, November
4, 2003
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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
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Appraisal Groups Support Department of Interior Appraisal Reforms
- AI-ASA-ASFMRA to the International
Valuations Standards Committee, October 29, 2003
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Comment letter on IVSC Consultative Paper on Valuation of Owner-Occupied Properties
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AI-ASFMRA-NAR to the Internal
Revenue Service, October 24, 2003
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Comments on the Draft IRS Real Property Valuation Guidelines
- AI Letter to the Editor of the Grand Forks Herald,
October 24, 2003
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Letter regarding Department of Interior Appraisal Reforms
- AI on the Implementation of the
Cabin User Fee Fairness Act of 2000, August 11, 2003
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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
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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
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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
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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
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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
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Groups state appraisers in no position to identify money laundering activities
- AI Letter to the Editor of the Wall Street Journal,
June 2, 2003
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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
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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
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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
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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
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Comment Letter to HUD in support of holding lenders equally accountable for appraisals
- AI-ASA-NAR on Appraisal Regulatory
Structure, January 24, 2003
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Letter to Sen. Richard Shelby, R-AL, detailing deficiencies in the appraisal regulatory
structure
- AI on HUD Strategic Plan,
December 13, 2002
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Letter to Secretary Mel Martinez on HUD’s long-term strategic goals
- AI-ASA on Third AQB Exposure Draft, December
3, 2002
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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
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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
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Letter to HUD detailing concerns about HUD RESPA reform proposal
- AI-ASA on Going Concern Value, October 23,
2002
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Letter to Small Business Administration expressing concerns on appraisal policies
and lending against going concern values
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AI-ASA-NAR on HUD Appraiser
Watch Initiative, September 18, 2002
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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
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Letter to HUD commenting on HUD’s inability to remove unqualified appraisers from
the FHA Appraiser Roster
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