1. Appraisal Subcommittee
Jim Park
Executive Director
Appraisal Subcommittee
ICAP
June 5, 2017
ASC Update
Thank you Ann and Craig
Disclaimer
This presentation may include opinions expressed by the speaker that do not necessarily represent the views or opinions of the ASC or its member agencies.

2. Appraisal Subcommittee (ASC) basics
Subcommittee of the Federal Financial Institutions Examinations Council (FFIEC)
12 staff members
Located in Washington, DC
$3.9 million budget (FY17)
Not supported by taxpayer funds (funded by $40 annual National Registry fee)
$659,000 in State and Appraisal Foundation grants (17% of budget)
Independent, Executive branch, government agency
4 staff members are currently credentialed or previously credentialed appraisers

3. ASC Member Agencies
The ASC is an independent executive branch federal government agency. Our board consists of 7 members:
FRB, OCC, FDIC (banking agencies)
NCUA, CFPB, HUD and FHFA
We are a subcommittee of the FFIEC which is made up of the same agencies with exception of HUD and FHFA.

4. Appraisal Subcommittee
State
Appraiser
Programs
ASB
AQB
Overview of the appraisal regulatory system. State focused system. The private sector, which can be much more nimble than state and federal government issues the qualifications and standards requirements. The states put them in place and the federal government’s role is to support the system.
Here is how the appraisal regulatory system is structured. The TAF boards establish the rules (uniform standards and minimum qualifications), the States employ those rules in their statutes and regulations policies and procedures and we (ASC) provide oversight to ensure States are following federal law.
It’s a partnership.
Appraisal Subcommittee
(ASC)

5. Title XI: Real Estate Appraisal Reform
Oversight of State Appraisal & AMC Programs
Monitoring & Review of Appraisal Foundation
Maintenance of National Registries (Appraiser/AMC)
Federal Grant to the Appraisal Foundation
Federal Grants to State Programs
5 main areas of responsibility given to us by federal law
We have written 4 regulations in 26 yrs.

6. State Appraisal Regulatory Programs reviewed at least once every 2 years
Guam
N. Mariana Islands
Virgin Islands
Puerto Rico
We visit the State regularly, at least once every two years for a complete on-site inspection and review of the State Program. We don’t do drive-by’s. Once the review is completed a final report is issued. It used to take well over 200 days to complete the review. We now have that down to less than 90 on average. All of the reports are publically available on our website.
It is a difficult job. Right now it is particularly difficult for States to keep up with the numerous changes being foisted upon them by the AQB Criteria changes, bi-annual USPAP changes, Dodd-Frank and the ASC.

7. Current state ratings 20 Excellent 24 Good 11 Needs Improvement
0 Not Satisfactory
0 Poor
At the present time, for the most part, States are doing very well with compliance.
These numbers reflect the current State ratings. As you can see no States are rated Not Satisfactory or Poor. 2 Need Improvement, 5 are Good and 10 States are Excellent.
Discuss old rating system. How quickly one State can go from first to worst.
Maryland had their last review in April and received a Good rating.

8. Excellent states South Carolina Colorado North Carolina Kentucky
Florida

9. State Disciplinary action history
Over 30,000 disciplinary actions including:
nearly 3,000 revocations
over 3,200 suspensions
close to 1,300 voluntary surrenders

10. appraiser Registry : www.ASC.gov
In order to be eligible to perform appraisals for federally related transactions:
Appraisers must be in active status on the Appraiser Registry
Another key responsibility of the ASC is operation of the National Registry.
The Registry is a database that shows which appraisers are active and eligible to perform appraisals for FRTs. It also shows any current suspensions, revocations or voluntary surrenders in lieu of discipline. Not only is the Registry used heavily by the States but most AMCs, lenders and other users of appraisal services, including the GSEs and FHA use the Registry continually to determine appraiser eligibility.

11. National registry of appraisers
First Registry (1991) was kept in the ASC office on a DOS database
1997 Registry included on the ASC website
Numerous database and website upgrades over the years
Approximately 3.2 million monthly hits
National Registry has been updated repeatedly over the years. It is now a crucial piece of the mortgage lending process.

12. 89,000
Many of seen different variations on this chart. It shows the history of credentials on the Registry.
Added mortgage origination projections.

13. National registry upgrades
Algorithm provided to States to create appraiser UID
Beta testing started April 3, 2017
Database release early Summer
Database changing from credential focus to individual appraiser focus
Improved data and reporting validation
Users to see future credential renewals

14. Notice of proposed rulemaking on AMC National registry fees
AMC Rulemaking
Notice of proposed rulemaking on AMC National registry fees

15. ASC amc fee rulemaking
Notice of Proposed Rulemaking on AMC National Registry Fees
Issued May 20 – July 19, 2016 (60 days)
104 comments (8 States)
Final rule on hold due to freeze on new regulations
Once that was completed it was up to the ASC to write a Rule establishing the AMC National Registry fee. Like the National Appraiser Registry, AMCs will have to pay a fee to be on the Registry.
We issued a proposed Rule in May this year for a 60 day comment period and we received 104 comments. 8 were from States.
By far, the majority of the commenters asked the ASC to bar AMCs from passing the national registry fees down to them. The reality is the ASC has no authority to bar that practice even if it wanted to.
We now have to go through a lengthy process of addressing the comments and writing a final rule.
Couple dozen attorneys from 8 federal government agencies involved
Shooting for mid 2017

16. Policy statement revisions
New Policy Statements for State AMC Programs
Revised Policy Statement for State Appraiser Programs
On hold due to freeze on new
regulations

17. Economic Growth and regulatory Paperwork reduction act
Raised commercial threshold from $250,000 to $400,000
Interagency Advisory on the Availability of Appraisers
Temporary Practice Permits
Temporary Waivers
FRT Definition
Federal banking agencies recently released the long awaited for EGRPRA report. A lot of interesting information (only 430 pages). Proposes to raise the commercial deminimus to $400,000, discussed raising the deminimis for business loans secured by real estate from $1 million to $2 million and left the residential threshold at $250,000.
Reminds that the States have the authority to issue TPP. In facts States must issue TPPs and over the past 2 years have issued well over 16,000 TPPs.
Also, the ASC, with FFIEC concurrence, has the authority to issue temporary waivers of appraiser licensing requirements in a State or certain geographical or political subdivisions.
Also made it clear the FRTs are a very small segment of lending, 10% or less.

18. FTC vs Louisiana Real Estate Appraisers Board
Complaint alleges price fixing and restraint of trade by Board
Louisiana issued statement commenting on the FTC complaint

19. My contact info:
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