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ASC Makes Progress on AMC National Registry Fee and State AMC Program Standards 

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.


Last month I attended a meeting of the Appraisal Subcommittee (ASC) for the Federal Financial Institutions Examination Council held in Washington D.C.

The Sept. 13 meeting involved two items previously put on hold due to the rule moratorium by the Trump administration that have since been resurrected by the Office of Management and Budget. Once finalized, these items will undoubtedly impact our industry.

They include:

  • AMC National Registry Fee — The National AMC fee will be collected by individual states and will then be transmitted to the ASC. The final rule states that the State will collect $25 per appraiser that has completed work for an AMC on a “covered transactions” in a previous 12-month period and transmit those funds to the ASC. The ASC will then use that money for grants back to the states. The rule goes into effect Nov. 24 and can be read at: federalregister.gov
  • Revised ASC Policy Statements — The policy statements are directives to state appraisal boards that require a State, if it elects to have an AMC program, to set minimum standards that it must maintain and also stipulates what the ASC will be inspecting for compliance. These policy statements are out for public comment until Nov. 20 and can be read at: federalregister.gov

Pro Teck will continue to monitor this situation, and as always will make sure our clients are compliant with all state and federal law.

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).

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