The National Fair Housing Alliance® (NFHA™) and the undersigned civil rights and consumer
advocacy organizations appreciate the opportunity to comment on the Advance Notice of
Proposed Rulemaking (ANPR), which, among other things, suggests replacing the Minimum
Property Requirements for appraisals for VA-Guaranteed and Direct Loans with the property
appraisal Condition Ratings in the Fannie Mae Single-Family Selling Guide (Fannie Mae Guide)
and the Freddie Mac Single-Family Seller/Servicer Guide (Freddie Mac Guide) (collectively, the
GSE Guides).
For the reasons described below, we urge the VA to:
- Recognize that the broad discretion allowed in the Condition Rating increases the risk of appraisal discrimination, and
- Conduct the appropriate analysis under fair lending laws and the Fair Housing Act’s Affirmatively Furthering Fair Housing (AFFH) provision.
We commend the VA for seeking input on this important topic and we hope that our comments will help inform the VA’s views.