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From: Gloria McColgan [mailto:email@example.com]
Sent: Tuesday, December 30, 2008 10:53 AM
Subject: Proposed Interagency Appraisal and Evaluation Guidelines
Please consider the comments below regarding the proposed Interagency
Appraisal and Evaluation Guidelines superseding the 1994 Interagency
Appraisal and Evaluation Guidelines.
."If applicable, the appraisal should include
three approaches (cost, income and sales comparison ) to analyze the value
of a property..." This proposed revision would require application of three
approaches for most commercial property appraisals, even if not necessary
for credible valuation results.
The proposed revision has the potential to increase appraisal fees and
appraisal delivery times for the Banking Industry due to additional
unnecessary research required to comply with the guideline. It also
partially negates the USPAP 2006 Scope of Work Rule.
Under the USPAP The Scope of Work Rule an appraiser must: 1. Identify the
problem to be solved; 2. Determine and perform the scope of work necessary
to develop credible assignment results; and 3. disclose the scope of work in
The Scope of Work Rule allows the appraiser flexibility in determining
what is necessary to develop credible assignment results under the intended
use. While various approaches may be applicable, they may not be necessary
to produce credible assignment results.
Recommendation: Revise to:
"The appraisal should include all necessary
approaches for the intended use".
Gloria T. McColgan MAI
|Last Updated 01/05/20098||Regs@fdic.gov|