April 11, 2007 Office of the Comptroller of the Currency Regulation Comments 250 E Street, SW, Mail Stop 1-5 Chief Counsel’s Office Washington, DC 20219 Office of Thrift Supervision 1700 G Street, NW Jennifer J. Johnson Washington, DC 20552 Secretary Board of Governors of the Federal Reserve Mary Rupp System Secretary of the Board 20th Street and Constitution Avenue, NW National Credit Union Administration Washington, DC 20551 1775 Duke Street Alexandria, VA 22314-3428 Robert E. Feldman Executive Secretary Attention: Comments Federal Deposit Insurance Corporation 550 17th Street, NW Washington, DC 20429 Re: OCC 2007-0005 Fed Docket No. OP-1278 OTS Docket No. 2007- 09 NCUA No. 2007-09 To Whom It May Concern: On behalf of the more than 30,000 members of our respective professional appraisal organizations, thank you for the opportunity to comment on the proposed Statement on Subprime Mortgage Lending. This statement addresses emerging issues and questions relating to subprime mortgage lending practices, discussing risk management and consumer compliance processes, policies and procedures that institutions should implement to respond to these concerns. We wholeheartedly support the issuance of guidance on subprime mortgage lending, highlighted by the burgeoning foreclosure problem in that market and the collapse of several subprime mortgage lenders in recent weeks. Undoubtedly, lax or poor lending practices have ...