TAVMA POSITION ON APPRAISAL INSTITUTE PROPOSAL FOR NEW APPRAISAL MANAGEMENT COMPANY (AMC) REGISTRATION AND REGULATION
The following are excerpts from the Title/Appraisal Vendor Management Association’s (TAVMA) position paper on the Appraisal Institute’s AMC Registration and Regulation Proposal. Download TAVMA Position Paper - AMC Regulation
"The Appraisal Institute (“AI”) has proposed a model act to register and regulate Appraisal Management Companies (“AMCs”). It contains many of the requirements recently proposed in the GSE – New York AG “Code of Conduct”, as well as the proposed and updated inter-agency guidelines. The AI proposal suggests sweeping new requirements for AMCs overall, including new rules for the owners, managers and appraisal-related employees of AMCs. It would give state appraisal boards the right to review AMC fee schedules, and to address the appraiser pressure issue."
Summary of the AI Proposal The AI’s proposed Model Act would provide a basic framework for use by the various state appraisal boards in registering and regulating AMCs. The registration process would require:
- basic information about each AMC, with office address and contact person(s);
- hiring and training controls and certifications for AMC employees;
- a one-year ‘license” for each AMC to operate in the state, and an annual fee;
- a ‘consent to service of process’ for litigation purposes;
- and contain four (4) exemptions for certain types of non-AMC usage of appraisers and minimal use of appraisers by AMCs (less than 10 appraisal orders per year).
A copy of the draft model legislation is available at: www.appraisalinstitute.org/newsadvocacy/downloads/modelprovisionsAMC.pdf.
"Over the last twenty-five years, lenders needed to automate and better manage the appraisal process, and AMCs helped to address these business needs. Lenders now frequently outsource the management of ordering, reviewing and delivering quality appraisal products and services to AMCs."
"AMCs are not appraisers, nor do they perform appraisals. AMCs are agents of lenders and are actually the clients of appraisers under USPAP, acting on behalf of their lender/clients. In fact, AMCs are clients of appraisers, not an extension of them."
"Therefore, it would be inappropriate and a serious conflict of interest for state appraisal boards, consisting mainly of appraisers, to regulate AMCs."
For the complete position paper: Download TAVMA Position Paper - AMC Regulation
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- Battle brewing over new appraisal rules - Chicago Tribune
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