8 — November 2025 — Appraisal Institute Southern NJ Chapter — M id A tlantic Real Estate Journal
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Appraisal Institute Urges Stronger Oversight, Clarity, and Innovation Balance in Valuation Policy at EGRPRA Hearing At the Economic Growth and Regulatory Paperwork Reduction Act (EGRPRA) public hearing held on Oct. 30, 2025, Deb Clark, MAI, Certified General Appraiser and Vice Chair of the Appraisal Institute’s Government Relations Committee, urged federal banking regulators to strengthen oversight of evaluation practices, harmonize state and federal valuation standards, and ensure that technological innovation in valuation operates within a framework that preserves public trust. Clark testified before representatives of the Office of the Comptroller of the Currency (OCC), Federal Reserve, Federal Deposit Insurance Corporation (FDIC), and National Credit Union Administration (NCUA). Her remarks centered on maintaining “integrity, quality, and public trust in real estate valuations” while ensuring that regulatory approaches evolve with modern lending practices and technology. Strengthening Oversight of Evaluations Clark began by emphasizing that appraisal exemption thresholds — which determine when an appraisal versus an evaluation is required — have significant implications for how lenders manage risk and cost. Any changes, she said, should be grounded in data and supported by strong quality controls. While recognizing that evaluations play an important role in the safety and soundness of the financial system, she noted that “banks’ internal evaluation programs vary widely in quality and oversight.” The Appraisal Institute, she said, recommends that regulators reopen the Interagency Appraisal and Evaluation Guidelines to establish clearer expectations for evaluation quality control. Clark proposed that institutions periodically test internal evaluations through independent validation, mirroring new quality-control standards for automated valuation models (AVMs) taking effect this month. “Applying similar testing to evaluations would help ensure that in-house valuation processes are credible, consistent, and defensible,” Clark said. She added that such a framework benefits all parties—helping institutions strengthen programs, bolstering public confidence, and giving regulators a clear method to assess whether internal evaluations meet safety and soundness standards. Clarifying the Role of Professional Appraisers Clark reaffirmed that professional appraisers—who meet rigorous education, experience, and ethical requirements—remain central to credible collateral valuation. She noted that the ability of appraisers to perform evaluations is complicated by a patchwork of state laws, with some states allowing evaluations outside of USPAP, others requiring USPAP compliance, and others remaining silent on the matter. “We encourage the agencies to work with state regulators to clarify and harmonize these requirements so appraisers can contribute their expertise wherever possible,” Clark said. “The goal isn’t to limit who performs evaluations, but to ensure all valuations are credible, reliable, and ethical.” Aligning Innovation with Accountability Clark also highlighted the rapid growth of artificial intelligence, automation, and data analytics in valuation practice, noting both their potential and the need for guardrails. “While these tools can improve efficiency and objectivity,” she said, “they must operate within a framework that preserves independence, transparency, and accountability.” She called on the agencies to establish clear standards for model validation, data governance, and human oversight when technology influences collateral-risk decisions. “Appraisers are well positioned to validate data, interpret results, and ensure that automated conclusions are reasonable,” Clark said. Closing Emphasis on Partnership and Trust In her closing remarks, Clark reiterated the Appraisal Institute’s commitment to working collaboratively with regulators, lenders, and other stakeholders. “Sound valuation depends on combining innovation and efficiency with the human judgment, independence, and ethics that define our profession,” she said. “The Appraisal Institute stands ready to work with the agencies to modernize valuation policy while maintaining safety, soundness, and public trust.” Banker Comments on Appraisals During the hearing, another witness raised concerns about appraisal requirements associated with higher-priced mortgage loans, citing potential operational burdens. However, toward the end of the session, when one of the regulators invited panelists to share any additional comments or concerns related to appraisals or appraisers, none of the witnesses chose to weigh in. The absence of further criticism underscored the constructive tone of the discussion and the recognition that professional appraisal remains an essential safeguard in the nation’s real estate finance system. What’s Next The EGRPRA review—conducted once every ten years—requires federal banking agencies to identify regulations that may be outdated or unnecessarily burdensome. The process will continue through 2025, with additional outreach sessions and opportunities for public comment expected. As regulators deliberate potential changes, the Appraisal Institute will continue to advocate for: • Stronger quality controls on internal evaluation programs; • Clear and consistent state and federal guidance on appraisers’ ability to perform evaluations; and • Balanced oversight that integrates innovation while preserving independence and public confidence. Clark’s testimony reinforced that credible, professionally guided valuation remains a cornerstone of financial stability and consumer protection—and that modernization must strengthen, not weaken, those foundations.
2025 OFFICERS AND DIRECTORS
President: Maria Nucci, SRA, AI-RRS
Vice President: Meghan Linaris, MAI
Treasurer: Deborah Tordella, MAI, SRA
Secretary: Joshua Garretson, MAI, AI-GRS, AI-RRS Past President: Sherrie Lisa Galderisi, SRA, AI-RRS Directors: Steve Bartelt, MAI, SRA, AI-GRS Michael Descano, MAI Danielle Fischer Lee Ann Kampf, MAI
Jerry McHale, MAI Errett Vielehr, MAI
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