Testimony of ABA's Sharon Whitaker on Appraisal Bias

The American Bankers Association (ABA) is pleased to be invited to the Appraisal Subcommittee's (ASC) third public hearing on Appraisal Bias. Thank you for the opportunity to speak to each of you on behalf of ABA and our members on the important topic of how lenders use appraisals.

Banks are committed to fairly serving the individuals, families and businesses in their communities and oppose discrimination in any aspect of the lending process, including appraisals. ABA and members have been discussing features of bank policies and procedures that promote the accuracy of an appraisal and support the ability of all residential borrowers to request a Reconsideration of Value (ROV).

Below we offer our responses to multiple questions posed by the ASC staff. Some of the questions and responses are combined to streamline the response.

• Please describe any efforts the ABA or its member banks have taken to address appraisal bias.
• What support does ABA provide for the reconsideration of value process and how do you encourage your members to use it? How successful has that process been in helping banks to identify and address appraisal bias?

ABA has an Appraisal Working Group for bank members, which meets monthly by Zoom to discuss appraisal-related topics, including peer discussions on how to identify and address appraisal bias. At these meetings, members also share how they have implemented processes that include communications to borrowers about the ROV process.

Download the testimony to read the full text.