AI comments on proposed Regulatory Capital Rule
AI letter of support for the continued reliance on independent real estate valuations in determining loan-to-value ratios and assessing collateral risk within the capital framework.
Summary
The Appraisal Institute strongly supports the proposal’s emphasis on valuation independence. The
separation of valuation activities from loan production and underwriting functions remains a critical
safeguard against conflicts of interest and helps promote objective, market-based value conclusions.