Jeff Dickstein, Pro Teck’s Chief Compliance Officer, is responsible for Pro Teck’s adherence to all state, federal and industry regulations. With Notes from the Regulatory Road, Jeff provides timely commentary on what is happening in the industry.
The Association of Appraiser Regulatory Officials held its annual Spring Conference May 4-6 in Seattle — one of the main topics of discussion during the industry event was the final rule to implement collection and transmission of annual AMC registry fees.
Recently, the Appraisal Subcommittee (ASC) released a revised bulletin with updated dates for compliance — most notably when the National Registry of AMCs will be open, as well as the reporting requirements for states to enter AMCs on the AMC Registry. Read the full bulletin here.
Open Date for AMC Registry
According to the update, the ASC will open the registry to states no later than July 16, 2018. At that time, the states that elect to register and supervise AMCs will be able to enter AMCs on the AMC Registry if they have collected AMC registry fees in accordance with the final rule.
If an AMC does not appear on the AMC Registry after July 16 it does not mean the AMC cannot complete FRT assignments until the ASC starts reviewing states for compliance, which will be on June 4, 2020. Most states’ representatives have also stated that because of the June 4, 2020, date they will most likely begin fee collection and transmission in the first quarter of 2020.
Reporting Requirements for the AMC Registry
For a participating state to enter an AMC on the AMC Registry, the following items are proposed to be required by the state on the AMC Registry:
- State Abbreviation
- State Registration Number for AMC
- Employee Identification Number (EIN)
- AMC Name:
- Street Address
- Number of Appraisers (for invoicing registry fee)
- License or Registration Status
- Effective/Expiration Date
- AMC Type (State or Multi-State)
- Disciplinary Action
- Effective/Expiration Date
Important Compliance Dates to Remember
By Aug. 10, 2018, a state needs to have policies in place to be in compliance with the AMC Registry rule. If a state does not plan to have its policy in place by Aug. 10, the ASC can issue a 12-month extension to Aug. 10, 2019. The extension request needs to be filed with the ASC prior to Aug. 10. The ASC prefers that any extension request be submitted by June 1, 2018, for proper processing and review. A number of states still need time to verify their Laws and Rules to give them authority to collect those fees and transmit to the ASC. As of today, the ASC has granted seven requests for a twelve-month extension.
Jeff Dickstein, Pro Teck’s Chief Compliance Officer, is responsible for Pro Teck’s adherence to 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 36 years, with more than 29 years of experience as an appraiser (he is a Certified Residential Appraiser in 17 states).