PolitiKit

Over reliance on Automated Valuation Methodologies (AVMs) poses a significant risk for Canadian consumers, lenders and the financial system. The best option to minimize the lending risk for mortgage properties is to have an on-site appraisal conducted by a third-party appraiser to determine the occupancy, the condition of the property, the neighborhood characteristics, and ultimately, the existence of the property. AIC supports AVM regulation and the role of appraisers being recognized directly in federal legislation through the Bank Act.

Downward pressure on appraisal fees and increasing demand for quicker turnaround times, combined with the restrictions on accessing good and reliable data, may ultimately drive professional appraisers away from completing mortgage finance work. This places a much higher risk for lenders and for Canadian consumers.

The AIC believes a holistic approach to supply needs to be considered, where industry and municipal, provincial and federal governments all work together if there is any possibility for solving the lack of inventory and encouraging affordable housing prices.

AIC is supporting OSFI Residential Mortgage Underwriting and Mortgage Insurance Practices and Procedures encouraging Federally Regulated Financial Institutions to employ sound valuation practices to determine the value of collateral used to secure and insure mortgages. Requiring FRFIs to apply proper due diligence by requiring valuation reports based on on-site, in-person inspections performed by qualified appraisers is a sound practice. It enables lenders to confirm the current valuation of the collateral when processing a mortgage loan application and provides the assurance that they are doing so with a valuation carried out in a fair and objective manner. In summary, we recommend that the Government of Canada continue to mandate, enhance, and enforce strong valuation fundamentals within FRFIs.

Canadian consumers require additional education on the full range of fees associated with mortgage financing and refinancing as well as the role of various professionals involved in the transaction. A disclosure of all fees incurred as part of obtaining a loan should be a mandatory requirement for all lending institutions - federally and non-federally regulated – to ensure that Canadians understand the financial commitment involved in what is often the largest investments in their lifetime. This includes the appraisal management fee and the appraisal fee.