Appraisers FAQ
The role of the appraiser is to provide objective, impartial, and unbiased opinions about the value of real property—providing assistance to those who own, manage, sell, invest in, and/or lend money on the security of real estate. Appraisers assemble a series of facts, statistics, and other information regarding specific properties, analyze this data, and develop opinions of value. Each appraisal assignment challenges the appraiser’s ability to put analytical skills into practice, exercise sound judgment, and communicate effectively.
There are three federally recognized appraiser classifications: (1)State Licensed; (2) State Certified Residential; and State Certified General. The difference is the examination and the number of hours of education and experience required to obtain the credentials, in addition to the scope of practice permitted for each once the credential is obtained.
The basic outline for these classifications is detailed in the publication entitled The Real Property Appraiser Qualification Criteria (AQB Criteria) as promulgated by the Appraiser Qualifications Board of the Appraisal Foundation. (http://www.appraisalfoundation.org)
A “yes” in the National Registry column identifying AQB Compliant means the appraiser met The Real Property Appraiser Qualification Criteria as promulgated by the Appraiser Qualifications Board on education, experience, and examination, when obtaining and/or maintaining the credential. A “no” in the column typically means the appraiser was not required to demonstrate the hours of experience set forth in the AQB Criteria for the credential level. It may also mean the appraiser failed to demonstrate the hours of education or continuing education set forth in AQB Criteria.
All appraisers with a status identified as active on the National Registry are eligible to perform appraisals in connection with federally related transactions within their allowed scope of practice. Certain users of appraisal services may elect not to use individuals who have a “no” in the AQB compliant column. A “no” indicates the individuals have not demonstrated to the State they possess the AQB Criteria minimums in every respect. The purpose of the AQB compliant column on our website is to aid those users in identifying these individuals. To achieve AQB compliance, appraisers may be able to submit the information in the deficient area(s) sufficient to demonstrate they now meet AQB Criteria. Appraisers wishing to have their “no” changed to “yes” must contact their State Appraiser Regulatory Agency to obtain the appropriate application procedure.
The Real Property Appraiser Qualification Criteria as promulgated by the Appraiser Qualifications Board of the Appraisal Foundation may be viewed in its entirety on http://www.appraisalfoundation.org/.
Visit the HUD website: http://www.hud.gov/groups/appraisers.cfm
AMC Regulation FAQ
The appropriate agency to receive your concern about a creditor’s compliance with the Truth in Lending Act (TILA), including the requirement for the creditor or the creditor’s agent (includes AMCs) to pay an appraiser a customary and reasonable fee, is the agency that enforces TILA with respect to the creditor.
For a Federally insured credit union, the National Credit Union Administration is the appropriate agency.
For insured depository institutions of more than $10 billion and their affiliates, the Consumer Financial Protection Bureau (CFPB) is the appropriate agency.
For insured depository institutions of $10 billion or less, there are two websites to find the federal regulator for a creditor: Federal Reserve System – National Information Center website: http://www.ffiec.gov/nicpubweb/nicweb/nichome.aspx
FDIC website at the “Bank Find” webpage: http://www2.fdic.gov/idasp/main_bankfind.asp
For other non-depository institutions, the appropriate agency to receive the complaint is the CFPB or the Federal Trade Commission.
Questions regarding the appropriate interpretation of the Truth in Lending Act, including those on customary and reasonable fees, should be directed to the Consumer Financial Protection Bureau, Office of Research, Markets and Regulation (William.Matchneer@cfpb.gov).
If the concern regards payment of customary and reasonable appraisal fees is related to a specific appraisal assignment or assignments, you can also contact the State appraisal board or agency in which the property or properties are located to find out if they have enacted appraisal laws and/or regulations that address your concern.