The Appraisal Subcommittee (ASC) of the Federal Financial Institutions Examination Council (FFIEC) was created on August 9, 1989, pursuant to Title XI of the Financial Institutions Reform, Recovery, and Enforcement Act of 1989 (Title XI). Title XI’s purpose is to “provide that Federal financial and public policy interests in real estate transactions will be protected by requiring that real estate appraisals utilized in connection with federally related transactions are performed in writing, in accordance with uniform standards, by individuals whose competency has been demonstrated and whose professional conduct will be subject to effective supervision.”
Pursuant to Title XI, one of the ASC’s core functions is to monitor the requirements established by the States[1] for certification and licensing of appraisers qualified to perform appraisals in connection with federally related transactions. Title XI as amended by the Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010 (Dodd-Frank Act) expanded the ASC’s core functions to include monitoring of the requirements established by States that elect to register and supervise the operations and activities of appraisal management companies (AMCs).
The Dodd-Frank Act included amendments to Title XI. As amended, Title XI requires the ASC to:
1. monitor the requirements established by States –
for the certification and licensing of individuals who are qualified to perform appraisals in connection with federally related transactions, including a code of professional responsibility; and
for the registration and supervision of the operations and activities of appraisal management companies (AMCs)
2. monitor the requirements established by the Federal financial institutions regulatory agencies with respect to --
appraisal standards for federally related transactions under their jurisdiction; and
determinations as to which federally related transactions under their jurisdiction require the services of a State certified appraiser and which require the services of a State licensed appraiser
3. maintain a National Registry of State certified and licensed appraisers (Appraiser Registry) who are eligible to perform appraisals in federally related transactions
4. maintain a National Registry of AMCs (AMC Registry) that either are registered with and subject to supervision of a State appraiser certifying and licensing agency or are operating subsidiaries of a Federally regulated financial institution
5. transmit an annual report to the Congress not later than June 15th of each year that describes the manner in which each function assigned to the ASC has been carried out during the preceding year
6. establish and operate an appraisal complaint national hotline, including a toll-free telephone number and email address, for the referral of complaints concerning alleged violations of appraisal independence standards and/or Uniform Standards of Professional Appraisal Practice (USPAP)
7. monitor and review the practices, procedures, activities and organizational structure of the Appraisal Foundation (Foundation)
The ASC has seven members, each designated respectively by the head of their agency, including the Board of Governors of the Federal Reserve System (Federal Reserve), Bureau of Consumer Financial Protection (Bureau), Federal Deposit Insurance Corporation (FDIC), National Credit Union Administration (NCUA), Office of the Comptroller of the Currency (OCC), Federal Housing Finance Agency (FHFA), and U.S. Department of Housing and Urban Development (HUD).
[1] “State” refers to the 50 States, the District of Columbia, and four territories (Commonwealth of Puerto Rico, Commonwealth of the Northern Mariana Islands, Guam and United States Virgin Islands).
The Appraisal Foundation, a not-for-profit corporation formed in 1987. It serves as the parent organization for two boards: the Appraisal Standards Board (ASB) which is responsible for promulgating and maintaining the Uniform Standards of Professional Appraisal Practice (USPAP) and the Appraiser Qualifications Board (AQB) which establishes minimum credential criteria for appraisers performing work for federally related transactions, the Real Property Appraiser Qualification Criteria (AQB Criteria).
The ASB and AQB are independent boards of the Foundation which serve as the congressionally-authorized sources for establishing appraiser qualifications and appraisal standards for federally related transactions. In monitoring the Foundation, the ASC attends AQB, ASB and Board of Trustees (BOT) meetings. The ASC also provides comments on proposals when needed and reviews all final published documents regarding AQB Criteria and USPAP.
The ASC is authorized by Title XI to make grants in such amounts as it deems appropriate to the Appraisal Foundation, to help defray those costs of the foundation relating to the activities of the ASB and AQB.
• how to obtain a copy of USPAP, as well as questions and answers related to USPAP
• AQB Criteria
• periodic electronic publications for State regulators
• descriptions of current Foundation initiatives
To view and/or comment on current and past AQB and ASB exposure drafts please go to:
State Appraiser Certifying and Licensing Agencies
Title XI authorized States to establish State appraiser regulatory programs (Appraiser Programs) to assure the availability of State certified and licensed appraisers for the performance of appraisals in connection with federally related transactions. There are three federally recognized appraiser classifications: (1) State Licensed; (2) State Certified Residential; and (3) State Certified General. The difference in the classification is determined by requirements for examination, education and experience required to obtain the credential. The AQB Criteria sets forth the minimum requirements for each classification. States may establish requirements in addition to the minimum requirements in the AQB Criteria.
Title XI was amended by the Dodd-Frank Act to include additional duties for States, if they so choose, to: (1) register and supervise AMCs; and (2) add information about AMCs in their State to the AMC Registry. States electing to register and supervise AMCs must implement minimum requirements in accordance with the AMC Rule.
The ASC performs periodic Compliance Reviews of each Appraiser Program to determine compliance or lack thereof with Title XI, and to assess implementation of minimum requirements for credentialing of appraisers as established in the AQB Criteria. As a result of the Dodd-Frank Act amendments to Title XI, States with an AMC regulatory program (AMC Program) will be evaluated during the Compliance Review to determine compliance or lack thereof with Title XI, and to assess implementation of the minimum requirements for State registration and supervision of AMCs as established by the AMC Rule.
Federal Financial Institutions Regulatory Agencies
The Board of Governors of the Federal Reserve System (Federal Reserve), the Federal Deposit Insurance Corporation (FDIC), the National Credit Union Administration (NCUA), and the Office of the Comptroller of the Currency (OCC) comprise the Federal financial institutions regulatory agencies (Agencies). Title XI requires each of the Agencies to prescribe appropriate standards for the performance of real estate appraisals in connection with federally related transactions (defined as those real estate-related financial transactions that an Agency engages in, contracts for, or regulates, and that require the services of an appraiser). These rules must require, at a minimum, that real estate appraisals be performed in accordance with generally accepted uniform standards as promulgated by the Appraisal Standards Board (ASB) of the Appraisal Foundation, that such appraisals be in writing and that such appraisals be subject to review for compliance with the Uniform Standards of Professional Appraisal Practice (USPAP). Such appraisals are to be performed by individuals whose competency has been demonstrated and whose professional conduct is subject to effective State supervision. Agencies may require compliance with additional standards if it makes a determination that such additional standards are required in order to properly carry out its statutory responsibilities. Each of the Agencies has adopted additional appraisal standards. These guidelines and other guidance can be found by accessing the individual Agency websites provided in the Quick Links.