Dear Tennessee Appraisers / TAC Members:
Many of you have been following the TriStar Bank issue. In November, TriStar Bank of Dickson, TN submitted a request to the Appraisal Subcomittee (ASC) for a waiver of certain requirements of Title XI or FIRREA. More specifically, they requested a waiver from the requirement of using state certified appraisers for appraisals made in the Nashville MSA. If approved, the waiver would apply to all banks in the Nashville MSA, not just TriStar Bank.
The ASC sent TriStar Bank two letters requesting additional information and TriStar Bank eventually responded last month. The ASC has not released this letter to the public and is treating it as confidential. We disagree with this stance and the lack of transparency in the process of evaluating the waiver request. The letter was also provided to the Tennessee Real Estate Appraiser Commission and they have submitted a letter of strong opposition to the waiver request. A copy of that letter is attached to this email.
The Tennessee Appraiser Coalition has been monitoring this situation closely and has also signed several letters of opposition to the waiver request. Today, TAC signed a letter to the ASC from 20 appraiser associations and coalitions from across the country. A copy of the letter is also attached to this email.
One of our board members has also filed an Open Records Request with the State of Tennessee to try to obtain a copy of the response letter from TriStar to the ASC. The ASC has stated that although it is treating the letter as confidential, it has not instructed TREAC what it can and can't do with the letter. Hopefully, the State will comply with the Open Records Request. We believe it is important that all appraisers and others affected by the waiver request be allowed to review the response letter from TriStar in order to provide any additional information to the ASC that would be relevant to their decision making process. The ASC could possibly have an internal briefing on this matter as early as tomorrow 2/14/18. Although it has not been made 100% clear by the ASC, it is our understanding that the process going forward could include a denial of the waiver request or the opening up of a public comment period and formal consideration of the request.
This is certainly an important issue and one that would set a dangerous precedent if approved by the Appraisal Subcommittee. We will relay any new information to you as it arises and will continue to strongly oppose this waiver request.