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Return to Comments
Collateral Evaluation Rule
Type: Regulation
Federal Register Document Type: Proposed
Appraisal Reporting Requirements

Text of Comment Letter
I wish to comment on one part of the above proposed rule.  I know that comments were due by 7/19/2021, but this just got pushed back on my desk and I missed it.  So, my comment may not be able to be considered and I understand that and know it is my fault, but I still wanted to share my comment.  My professional summary is attached so you will know something about my background.

The last sentence in item #5 regarding providing copies of appraisals/evaluations states: “Additionally, we believe the information provided in the documentation should be presented in a manner that is easily understood by the applicant or borrower.”

The normal intended user of an appraisal for mortgage lending is an employee of the lending organization, in this case, a Farm Credit employee.  USPAP requires that the appraiser write his appraisal so that It can be understood by his intended user.  This appraiser can accurately gauge the knowledge of USPAP of his Farm Credit intended user, but is difficult for him to gauge that same knowledge by the applicant/borrower, who he may not know.  An appraisal written to the knowledge level of the Farm Credit employee, may or may not, be understood by the applicant/borrower.  If the intent of the FCA regs is for the applicant/borrower to be an intended user, it vastly complicates the appraisal process, and related expense, for Farm Credit institutions.   I would suggest that the regulations make it clear, that although the applicant/borrower is to receive a copy of the appraisal report, the applicant/borrower is not to be considered an intended user as defined by USPAP.

Just my thoughts.  Sorry I didn’t make the time deadline.

Jim Cannon, ARA, MAI
Cannon, Lechtenberg & Assoc., Inc.
2908 N Plum, Ste B
Hutchinson, KS  67502
620-728-1310, Cell 728-8320