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Compliance Blog 6.24.2016
Notes from Regulatory Road – June Edition

Nice upscale homes on suburban street

Information is the key to making sensible decisions. In our industry, the sheer number of new rules and regulations are staggering. This month, there are some important rules being finalized:

The Appraisal Subcommittee (ASC) Proposed Rule to Implement Collection & Transmission of Annual AMC Registry Fees

The Appraisal Subcommittee (ASC) provides federal oversight of State appraiser regulatory programs and a monitoring framework for the Appraisal Foundation and the Federal Financial Institutions Regulatory Agencies. The proposed rule, which includes three options for collecting a $25 fee per year for each appraiser working for an AMC, can be read here. The basic difference involves what constitutes “working for or contracting with” an AMC.

Comments are being accepted through July 19, 2016 on which of the three options for collection of fees will be instituted.  The three options are:

  • Option one: The phrase ‘‘working for or contracting with’’ would be interpreted to include every appraiser on an AMC appraiser panel during the reporting period, regardless of if they had performed an appraisal during the time.
  • Option two: The phrase ‘‘working for or contracting with’’ would be interpreted to include those appraisers engaged by the AMC to perform an appraisal on a covered transaction during the reporting period in a particular state.
    • In this option, if an AMC has an “invite” model to assigning appraisals, all those invited to do the work (even if they performed no appraisals) would be counted towards the fee.
  • Option three: The phrase ‘‘working for or contracting with’’ would include all appraisers that perform an appraisal for the AMC on a covered transaction during the reporting period in a particular state.
    • This option would exclude appraisers accepted by the AMC for consideration for future appraisal assignments as well as appraisers who performed appraisals in the past but did not during the reporting period.

Pro Teck supports Option 3 because it allows an AMC to actively manage its panel, bring new appraisers on and guarantee that its clients are getting the best appraisers to do their appraisals. Also, this option would have the least impact on consumers, who are already feeling the financial impact of new regulation and processes.

Appraisal Standards Board (ASB), 2018-19 changes to USPAP

The Appraisal Standards Board (ASB) issued its first exposure draft for 2018-19 changes to USPAP. The draft can be viewed here.

The ASB issued a Discussion Draft in January 2016 identifying potential areas of change for the 2018-19 edition of USPAP. The Discussion Draft addressed:

  • Communication of Assignment Results and definition of report
  • STANDARD 6, Mass Appraisal, Development and Reporting
  • Definition of assignment
  • Review of terms, assumption and extraordinary assumption
  • STANDARD 3, Appraisal Review, Development and Reporting
  • Review of Standards Rules 7-2(c), SR 7-5, and 8-2(v)
  • Review of Standards Rule 8-3 · Review of Advisory Opinions
  • Other edits to improve clarity and enforceability of USPAP

Comments were due by June 10, 2016 – I’ll let you know of any substantive changes.

Appraisal Qualifications Board (AQB), Proposed Changes to the Real Property Appraiser Qualification Criteria

The Appraisal Qualifications Board (AQB) issues an exposure draft of proposed changes to appraiser qualifications – it can be read here.

In response to the Discussion Draft, the AQB received over 270 written comments, as well as a number of verbal comments at a public meeting held in Phoenix, AZ on April 8, 2016. This exposure draft takes into consideration all comments received to date, and will focus on the following five major areas in the criteria:

  • Alternative Track for Licensed Residential to Certified Residential
  • Enhanced Practicum Curriculum
  • Documenting Alternative Experience
  • “Trainee” Nomenclature
  • Three-Year Supervisory Residency Requirement

Pro Teck applauds all efforts to ensure that appraisers are well trained, and supports any plan to make the profession more attractive to new appraisers.


Jeff Dickstein, Pro Teck’s Chief Compliance Officer, is responsible for Pro Teck’s adherence with all state, federal and industry regulations. He’s active with a number of industry boards, and is currently Chairman of The Appraisal Foundation’s Industry Advisory Council.

Jeff has been in the mortgage industry for thirty-five years, with more than twenty five years’ experience as an appraiser (he is a Certified Residential Appraiser in 15 states). With Notes from the Regulatory Road, Jeff will provide timely commentary on what is happening in the industry.