July 23, 2025
The Honorable Michelle Bowman
Chair
Federal Financial Institutions Examination Council
c/o Federal Reserve Bank
1850 K Street NW
Washington, DC 20006
Dear Chair Bowman,
We write to express concerns about the current state of the operations of the Appraisal
Subcommittee (ASC). Accurate and reliable appraisals are critical for our residential housing and
commercial real estate markets and other infrastructure. Given current trends in the commercial
real estate sector, 1 high borrowing rates and increasing recovery costs from natural disasters, 2 it
is important that the appraisal system remain stable and well-managed. However, we are
monitoring concerns related to staffing shortages 3 and oversight of state appraisal offices, which
may be impacting appraisal quality. 4
To address these concerns effectively, we respectfully request the Council exercise its oversight
authority over the Appraisal Subcommittee and provide a detailed corrective plan outlining how
it will fulfill its responsibilities. Please respond to the below questions by August 29, 2025.
1. When will the ASC Board resume quarterly meetings?
2. When will the ASC Board fill any vacancies?
1
Doolittle, Tom and Fliegelman, Arthur, “Five Office Sector Metrics to Watch, Office of Financial Research, June 1,
2023. https://www.financialresearch.gov/the-ofr-blog/2023/06/01/five-office-sector-metrics-to-watch/
2
Acosta, Deborah, “The Worst Housing Market in America Is Now Florida’s Cape Coral,” The Wall Street Journal,
June 30, 2025. https://www.wsj.com/real-estate/florida-cape-coal-home-prices-3f64a0df?mod=itp_wsj,djemITP_h
3
Jones, Sasha, “U.S. Appraisal Oversight Body Quiet For 7 Months, Now Running With 30% Smaller Staff,”
Bisnow, July 02, 2025. https://www.bisnow.com/national/news/capital-markets/government-entity-regulating-
appraisers-cuts-staff-limits-meetings-130028
4
Wasielewski, Matt, “Lawsuit Alleges Appraisal Institute Has Given States Fraudulent Test Results For Years,”
Bisnow, March 29, 2025. https://www.bisnow.com/national/news/commercial-real-estate/lawsuit-accuses-appraisal-
institute-of-giving-states-fraudulent-test-results-for-years-128719
3. What is the time frame for recruiting and hiring a permanent Director? Will that Director
have housing and finance expertise?
4. What changes are planned, if any, to reorganize the agency and ensure that website
disruptions no longer occur?
5. How will current staffing vacancies be filled and in what time frame? 5
6. What changes have been made to the supervision process? Please define any new
changes in the manual and what those impacts have been on states and territories.
a. We are concerned that some state biannual exams are being conducted by only
one examiner, instead of the two or three as in previous years. If solo examiners
are a new practice, please explain how the ASC will ensure a comprehensive,
accurate and fair exam.
b. Are there any compliance reviews for states or territories that are behind
schedule?
c. Were changes to the exam process made in a way that resulted in changes to
scores? If so, what changes were made that affected which states or territories?
d. How has the board investigated the allegations of fraudulent test results? 6
Thank you for responding by August 29, 2025 to these questions and ensuring the appraisal
sector operates in a way that is accurate, fair and professional.
Sincerely,
Catherine Cortez Masto M. Michael Rounds
United States Senator United States Senator
5
Jones, Ibid.
6
Wasielewski, Ibid.
CC: Mr. Luke Brown, Acting Chairman, Appraisal Subcommittee
Ms. Elizabeth Davis, Member, Appraisal Subcommittee
Ms. Mary Aiken, Member Appraisal Subcommittee
Mr. Enice Thomas, Member, Appraisal Subcommittee
Mr. Ian Marenna, Member, Appraisal Subcommittee
Ms. Julie Giesbrecht, Member, Appraisal Subcommittee
