The feared undersupply of certified and licensed appraisers that caused mortgage lenders to seek legislative and regulatoryrelief from the requirement that they be used has not occurred.

'We haven't received a single request for a waiver,' said Edwin W. Baker, executive director of the appraisal subcommittee of the Federal Financial Institutions Examination Council.

This is because the supply of certified and licensed appraisers will be sufficient to meet the demand. he said, not because the size of the deal on which they are required was increased.

'The reason the lenders wanted the higher threshold was because they didn't want to pay outside appraisers.' asserted Baker. He said the current supply is about 60,000 and the total would reach 70,000 when the requirement for use of certffied or licensed appraisers goes into effect Dec. 31.

Donald E. Kelly, vice president for government affairs in the Washington office of the Appraisal Institute, said the FFIEC report is confirmation of what his organization has predicted aH along.

Samuel E. Pincich, manager of loan administration for the Savings and Community Bankers of America. said he has heard few complaints from members about the approaching deadline.

'If there is any shortage, it probably will provide an incentive for a lender to take the next step and get its own appraisers qualified,' he said. The Financial Institutions Reform, Recovery and Enforcement Act of 1989, which set appraisal standards, includes a requirement that federally regulated lenders have appraisals done by licensed or certified appraisers.

That requirement was originally scheduled to go into effect last Dec. 31 but the Federal Deposit Insurance Corporation Improvement Act of 1991 extended it to Dec. 31 of this year.

In addition to seeking the extension, the banks and thrifts also asked their regulators to raise the size of transaction on which the requirement would apply to $100,000. The regulators complied. The Federal Reserve Board was at $100.000 already. while the other regulatory agencies were at $50,000.

The Appraisal Institute threatened to challenge in court the authority of the regulators to increase the de minimis levels.

Congress blocked that route by an amendment in the Housing and Community Development Act of 1992 that expressly permits the agencies to set deminimis levels.

'We do not approve of those thresholds and continue to talk with the agencies about them.' said Kelly. who noted that the housing bill also calls for General Accounting Office studies after 18 months and 36 months to consider the impact of the higher thresholds.

He said the Appraisal Institute has not decided whether to ask Congress to lower the thresholds, but added that the organization plans to form a coalition with other groups, including affordable housing advocates. to collect data on the impact of the higher thresholds.

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