In the wake of the GAO study, stake holders, including several appraisal organizations, have submitted comments to Congress. A joint letter from American Society of Appraisers, American Society of Farm Managers and Rural Appraisers, Appraisal Institute and National Association of Realtors writes: “With a patchwork of state laws and ineffective federal oversight allowing for only “minimum” qualifications criteria for licensing and certification in some cases, states and the federal oversight bodies too often have not carried out their specific intended responsibilities to enforce the standards as required by the federal law.”

The letter also notes that since Title XI it has been difficult to achieve consistency among states with respect to the enforcement of standards and certification requirements. The letter says, “Whether through a lack of resources or a lack of will by those charged with providing oversight, the current system allows some unscrupulous and unqualified appraisers to continue practicing with little or no recourse for their actions. Having provided for only “minimum” qualification requirements, the implementation of FIRREA has failed to offer incentives for appraisers to seek additional training, education and experience. In the end, we believe the public would be better served by a system that encourages appraisers to excel through appropriate professional development.”

David Bunton, Executive Vice President of the Appraisal Foundation (TAF) said in response to the report, “While we are certainly not surprised, we are pleased to report that the GAO found no significant deficiencies with TAF's Boards or programs. This is particularly noteworthy, given the breadth and scope of several recent Board initiatives.”

According to the TAF, the GAO's final report recommends that the Appraisal Subcommittee (ASC) do the following: