WASHINGTON, D.C. – In a letter to Acting Administrator Marianne O’Brien Markowitz of the U.S. Small Business Administration (SBA), NACS, along with other groups, asked the agency to change a modification that disqualifies most real estate appraisers from doing “going concern” appraisals that satisfy a “change in ownership business valuation” rule.

The letter stated that the change in policy “will surely lead to increased costs for consumers and lenders who will now have to order and reconcile multiple appraisals for a single property. These costs will primarily affect main street businesses, like convenience stores, car washes, and motels.

“SBA continues to vacillate on this issue; in 2009, real estate appraisers were reportedly disqualified from approved lists to perform ‘going concern’ appraisals based on interpretations by some SBA regional offices. In 2011, SBA issued new guidance allowing an appraiser to take an accepted course in order to meet eligibility requirements. But now it seems SBA has substantially reverted to the 2009 version which has numerous problems, most notably significant costs and time delays.”

NACS, along with the other groups which signed the letter, requests that the agency “provide details and analysis as to why an experienced real estate appraiser does not qualify to prepare ‘going concern’ appraisals if the appraiser is experienced in the particular property type and is competent to value special purpose properties…. Further, please inform us as to whether or not SBA has conducted a comparison of state certification requirements for real estate appraisers and business appraisers. If so, what were the differences and did this play a role in this proposed policy change?”

NACS closes by reiterating its hope that SBA would clarify its thinking about appraisals and work with other small business groups to resolve it in a way that benefits all parties involved.