FR 2021-02816

The Department of Veterans Affairs (VA) is requesting approval from the Office of Management and Budget (OMB) to collect information under the Paperwork Reduction Act (PRA) of 1995. This particular request pertains to the "Lender's Staff Appraisal Reviewer (SAR) Application," a form that assists the VA in determining property values for loans that are automatically guaranteed. The agency's notice invites public comments on this data collection process, which must be submitted within 30 days of the notice's publication.

Concerns and Considerations

One issue with the document is the lack of clear reasoning for why this specific application form, VA FORM 26-0829, is necessary or beneficial. Without justifying its necessity, questions may arise regarding whether the resources allocated to this initiative could be better spent elsewhere. Furthermore, the document does not provide a detailed breakdown of the costs associated with the information collection. Such financial details would be helpful to understand potential areas of wasteful expenditure or cost-effectiveness, especially in today's fiscal environment where accountability is crucial.

The data collection impacts a limited number of respondents, with estimates suggesting only 20 people are involved annually. This raises questions about whether the process is disproportionately burdensome relative to its scope. Arguably, a larger number of respondents might justify the exercise. On the flip side, due to the low burden hours (2 hours annually with each response averaging 5 minutes), some might argue that maintaining the process signals due diligence by the VA, which is important for public trust.

Impact on the Public and Stakeholders

For the general public, this document may seem overly technical, and its implications might not be directly apparent. Notably, the notice's procedural aspect for public comment might be confusing and discourage individuals from participating. The inclusion of complicated terminology like "Servicer Appraisal Processing Program (SAPP)" and "reasonable value of property" could alienate those not well-versed in VA programs or legal jargon. Simplifying language and clarifying intentions could increase public engagement and transparency.

For specific stakeholders, such as lenders and appraisal reviewers, the document outlines a framework within which property value determinations can be standardized for VA loans. This could enhance service delivery consistency, benefiting veterans seeking guaranteed loans through efficient and recognized processes. However, for those directly impacted—namely the 20 respondents required to fill this form—the benefit might seem minimal compared to potential administrative inconvenience, particularly if they find the requirements complex or unnecessary.

Conclusion

In summary, the document represents an ongoing effort by the VA to comply with federal information collection standards and provide structured methodologies in loan appraisals. Despite its good intentions in standardizing certain procedures crucial for veterans' financial services, the execution and communication of this initiative could benefit from clearer rationale, simpler language, and more contextual transparency to engage a broader audience effectively. This would ensure both fiscal responsibility and improved stakeholder experience.