NAR Appraisal Foundation Comment Letter Regarding Appraiser Qualifications Board AQB Proposed Changes to Opinion 16

Issue Date: March 31, 2021


On March 31 NAR sent a letter to the Appraisal Standards Board. The letter provides comments in in response to the Appraiser Qualifications Board’s (AQB) Exposure Draft of Proposed Changes to Advisory Opinion 16 of the Uniform Standards of Professional Appraisal Practice (USPAP), Fair Housing Laws: Avoiding Bias in Real Property Appraisal and Appraisal Review Development and Reporting. NAR, as a sponsoring organization of the Appraisal Foundation (TAF) which oversees the AQB, fully supports efforts by the AQB to improve guidance and training for appraisers as it relates to fair housing law and diversity and inclusion matters.
 
Recent media stories and research papers highlighting problems with discrimination in real estate appraisal demonstrate that the appraisal industry as a whole must address the challenge of bias in valuation. The proposed changes to Advisory Opinion 16 are a step in the right direction. However, it is imperative that the AQB and TAF go further in the development of guidance for appraisers in terms of bias and discrimination. Simply updating Advisory Opinion 16 is not enough. The AQB should develop extended training related to compliance with the Fair Housing Act, as well as education focused on the recognition and prevention of bias that can arise in the appraisal process.