Vyacheslav Revetsky
In addition to professional market participants, bankers, including representatives of the National Bank of Moldova, showed serious interest in the discussion.
The meeting analyzed the opinions and proposals already received on the two departmental acts. The Framework Code of Ethics for Appraisers provoked a substantive discussion, during which the participants made proposals for its completion and concretization, aimed at strengthening the principles of integrity, impartiality and professional responsibility.
The discussion of the section “Valuation for Loan Guarantees” was quite active, the document was considered in full. Amendments were proposed regarding the minimum validity period of the appraisal report, the need to specify the recipient of the report, as well as issues related to the possibility of assessing the degree of construction completion at the direct request of the lender. One of the topics on which appraisers should provide additional opinions is the factors relevant to assessing the fulfillment of the guarantee required by paragraph 43 of the current version of the guidance.
Particular attention was paid to the annex containing the minimum requirements for a valuation report intended to secure a loan. Participants emphasized the need to detail certain aspects to ensure uniform and transparent application of the methodology, while providing banks and other lenders with a sound basis for the lending process.
As Veaceslav Revetschi, chairman of the National Society of Professional Appraisers of Moldova (SNEP), noted for Logos Press, there were no special questions regarding the Code of Ethics. Its provisions are taken from international documents and nothing new can be invented there. The Code of Ethics is general, but each association can supplement it with its own requirements that fit into the general principles of behavior of appraisers.
As for the Guide to Collateral Assurance, there were a lot of comments on the part of appraisers’ associations and individual specialists. Some of the authors of the draft accepted immediately, others were left to be clarified. “In principle, the discussion was constructive. Appraisers defended their positions, because the bank’s requirement should correlate with professional appraisal. We should be independent and free to choose the valuation methodology, and we will adhere to the framework established in this Guide,” says Vyacheslav Revetsky.
The question among appraisers was raised by the paragraph of the Guide, which set the minimum term for the preparation of an appraisal for collateral at three days. What if it is ready earlier? The explanation that this is the minimum term since all documents and necessary materials are received satisfied the appraisers. “I don’t see a problem there, no one forbids preparing the report earlier,” the SNEP chairman said.
Discussions were also sparked by the provision that the appraiser should determine, on the basis of knowledge and market research, whether it is worthwhile for the bank to pledge a particular object.
Even if there is no active market, the real estate object has some value anyway, and I, as an appraiser, can determine it, – says Vyacheslav Revetsky. – But it is the bank’s prerogative to decide whether to take it as collateral or not. And we suggest that the banks make a list of objects that they are ready to take as collateral, and which are not”.
