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On April 6, 2018, NAR submitted a comment letter to the Appraisal Subcommittee (ASC) concerning Tri-Star Bank's request for appraisal relief in the Nashville area and surrounding counties. NAR recognizes that true failures in the housing market sometimes require drastic government intervention. However, NAR does not feel that the request made by the Bank for a waiver of appraisal requirements for commercial Federally Related Transactions (FRT) demonstrates the type of market failure that would warrant extreme remedies. NAR was primarily concerned with errors in the data presented by the Bank and the remedies proposed by the Bank, including the use of REALTORS® to prepare valuations that would go against NAR's Responsible Valuation Policy.
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