Response to consultation on draft regulatory technical standards on independent valuers

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Q2: Do you agree that three years is the appropriate period of time for the purposes of Article 4(5)?

Yes, a period of three years seems appropriate to us and it is applicable to any service relationship, even for the audits mentioned under art. 4.7.

Q4: Do you reckon there are other cases of where independence should be ruled out in any case?

Yes, see our reply to Q1 and the annex with the relevant articles of Spanish legislation that identify some possible cases.

Q5: Do you agree with the approach outlined in the impact assessment and more specifically, with the elements included in the assessment of costs and benefits?

See previous answers from our organization whose profile is the folowing:La Asociación Española de Análisis de Valor is the organization that has undertaken the representation of the real estate valuation sector in Spain. Its members are valuers that represent practically 90% of the real estate valuations commissioned by Spanish credit institutions, albeit for the mortgage market, accounting purposes or in relation to solvency.
Our association’s replies to the main questions posed in the public consultation process that is included within the open framework for making comments and proposals regarding the DRAFT REGULATORY TECHNICAL STANDARDS ON INDEPENDENT VALUERS prepared by the EBA, are set forth below.

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