A form developed by the federal financial institution regulators and the consumer financial protection agency to facilitate formal complaints related to real estate appraisal practices is in the process of being renewed by the Office of the Comptroller of the Currency (OCC), which has issued a notice inviting comments until Dec. 26.
In its notice, OCC invites comments on the necessity, utility and regulatory burden cost of the Interagency Appraisal Complaint Form.
The form was developed by the OCC, Federal Reserve Board, Federal Deposit Insurance Corp. (FDIC), National Credit Union Administration (NCUA), and Consumer Financial Protection Bureau (now known as the Bureau of Consumer Financial Protection, or BCFP) to collect additional information on complaints referred to them via a hotline established by the Federal Financial Institutions Examination Council (FFIEC) Appraisal Subcommittee (ASC). The individual agencies created the Appraisal Complaint Form to collect information necessary to take further action on the complaint; the consumer bureau incorporated the process into one of its existing systems, the notice says.
The form is intended to be used by those wishing to file a formal, written complaint that an entity subject to the jurisdiction of one or more of the agencies has failed to comply with the appraisal independence standards or the Uniform Standards of Professional Appraisal Practice (USPAP).
As for the burden cost, the OCC estimates 100 users of the form annually, with each spending a half-hour to fill it out; that adds up to an estimated total annual burden of 50 hours.