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And the Assault Continues

Published on 12/6/2017

TriStar Bank, a Tennessee community bank, submitted a request to the Appraisal Subcommittee (ASC) for a temporary waiver of appraisals for 2018. This waiver would apply to all property types. The request is based on a reported shortage of appraisers resulting in increased fees and reduced turn times on appraisals.   Click Here to read the full letter.

Sources tell The Appraisal Buzz that local appraisers have responded by visiting the TriStar headquarters requesting to be put on their panel. This is simply genius. If you are a TN appraiser please reach out to them and request to be added to their panel. Andrew Deason can be reached at or 615-326-0532.

The Collateral Risk Network is preparing a comment letter now. We encourage appraisers in any state to comment to the ASC as well.  Click here to listen in to the Tennessee Real Estate Appraisal Commission (TREAC) meeting on November 28, 2018 with the specific discussion beginning at 1:56.

I warned Congress about the concerted efforts by multiple parties to diminish the role of the appraiser in my comments on November 16th, 2016 to the Subcommittee on Housing and Insurance (Committee on Financial Services).  Here is a link to watch the testimony again. Do not expect this to be the one and only request for appraisal waivers. Ironically this comes at a time when turn times have normalized across most of the US supporting my premise that the challenges have been created by bubblelicious activity. That is a threat and a battle we will take on another day!

In my personal opinion, all of these attacks upon the profession are in retaliation of the Home Valuation Code of Conduct (HVCC) and Appraisal Independence Requirements (AIR). There are a lot of stakeholders who have misaligned incentives to influence the outcome of an appraisal. While not excusable, it is understandable from a motivational perspective. But in the name of all that is holy, please help me understand how bank regulators can consider these waivers in the name of “safety and soundness”?