APPRAISAL SUBCOMMITTEE (ASC) BASICS

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Geraldine Hudson
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APPRAISAL SUBCOMMITTEE (ASC) BASICS Subcommittee of the Federal Financial Institutions Examinations Council (FFIEC) 12 staff members

1 4/16/2018 National Association of Appraisers April 8, 2018 Jim Park ASC Executive Director This presentation may include opinions expressed by the speaker that do not necessarily 1 represent the views or opinions of the ASC or its member agencies. APPRAISAL SUBCOMMITTEE (ASC) BASICS Subcommittee of the Federal Financial Institutions Examinations Council (FFIEC) 12 staff members Located in Washington, DC $3.6 million FY18 budget Funded by $40 annual National Registry fee State and Appraisal Foundation grants $660,000 (FY18) 2 1

2 ASC MEMBER AGENCIES 3 ASB AQB State Appraiser Programs Appraisal Subcommittee (ASC) 4 2

3 TITLE XI: REAL ESTATE APPRAISAL REGULATION 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 AMC Registry open no later than 6/4/18 ASC BULLETIN NO ASC will review participating States for compliance after 6/4/20 Established reporting requirements 6 3

12 months Extension requests should be made by 6/1/18 7 NATIONAL AMC REGISTRY Annual

4 Extension of Implementation Period for State AMC Programs ASC BULLETIN NO ASC, with FFIEC approval, may extend the Implementation Period (8/10/18) by 12 months Extension requests should be made by 6/1/18 7 NATIONAL AMC REGISTRY Annual Registry Fee Least costly approach allowable by law Income to ASC will be used for grants 8 4

5 4/16/2018 APPRAISER REGISTRY UPGRADES Database Effective and expiration dates added Unique ID

6 11 ECONOMIC GROWTH AND REGULATORY PAPERWORK REDUCTION ACT Commercial threshold increase from $250,000 to $400,000 Temporary Practice Permits Temporary Waivers 12 6

7 4/16/2018 TEMPORARY WAIVER REQUESTS Title XI allows temporary waiver of credentialing requirements IF: Scarcity of appraisers exists; AND Scarcity is leading to significant delays in appraisal services for FRTs Requires FFIEC concurrence 13 REQUEST FROM OTHER INTERESTED PARTIES (NOT A STATE AGENCY) Requirement(s) of State law from which relief is being sought Description of significant problems being encountered in efforts to comply with Title XI Nature of scarcity of credentialed appraisers (including supporting documentation) Extent of delays anticipated or experienced in obtaining services of credentialed appraisers (including supporting documentation) Reasons why requester believes that the requirement(s) are causing scarcity of credentialed appraisers and the service delays 14 7

8 REQUEST BY STATE AGENCY State agency request must include bulleted requirements on previous slide as well as two additional requirements: State agency must either submit a duly authorized written determination of scarcity of credentialed appraisers causing significant delays in obtaining appraisals for FRTs, or the State may ask the ASC for such a determination State agency must submit specific plan to expeditiously alleviate the problem 15 CURRENT TEMPORARY WAIVER REQUEST TriStar Bank, TN Requested waiver in Nashville MSA ASC publishednotice of Received Request for a Temporary Waiver; Request for Comments(Notice) in the March 9th issue of the Federal Register 16 8

4/16/2018 TEMPORARY WAIVER REQUEST ASC Special Meeting April 23 to determine if a scarcity of appraisers exists in the Nashville, TN MSA causing significant delays in obtaining FRT appraisals If a

9 4/16/2018 TEMPORARY WAIVER REQUEST ASC Special Meeting April 23 to determine if a scarcity of appraisers exists in the Nashville, TN MSA causing significant delays in obtaining FRT appraisals If a scarcity is found, ASC to determine which AQB Criteria (State law/regulation) waived/preempted and length of waiver Support for determination 17 November 13, 2017 OCC Washington, DC Headquarters The Evolving Real Estate Valuation Landscape Streamlining federal appraisal requirements Alternative/hybrid valuations 18 9

10 SAMPLE ASCROUNDTABLE SUGGESTIONS Allow licensed appraisers to perform appraisals for HUD/FHA Improve ability to transfer appraisals between institutions Consider bifurcating USPAP into residential and non-residential 19 SAMPLE ASCROUNDTABLE SUGGESTIONS Improve consistency of federal regulatory examinations Abbreviate/simplify engagement letters Improve/streamline trainee to credentialed appraiser requirements Update GSE appraisal forms 20 10

11 S.B SEC. 103 Exemption from appraisals or real property located in rural markets Appraisals not required if: Property is located in a rural area o Within 3 days of providing the Closing Disclosure Form to the consumer o Mortgage originator has contacted at 3 State Licensed or Certified Appraisers 21 S.B SEC. 103 has documented that no State certified appraiser or State licensed appraiser, as applicable, was available within 5 business days beyond customary and reasonable fee and timeliness standards for comparable appraisal assignments, as documented by the mortgage originator or its agent; the transaction value is less than $400,000; and the mortgage originator is subject to oversight by a Federal financial institutions regulatory agency

12 S.B SEC. 103 SALE, ASSIGNMENT, ORTRANSFER. A mortgage originator that makes a loan without an appraisal under the terms of subsection (b) shall not sell, assign, or otherwise transfer legal title to the loan unless (1) the loan is sold, assigned, or otherwise transferred to another person by reason of the bankruptcy or failure of the mortgage originator; (2) the loan is sold, assigned, or otherwise transferred to another person regulated by a Federal financial institutions regulatory agency, so long as the loan is retained in portfolio by the person; 23 S.B 2155 SEC. 103 (3) the sale, assignment, or transfer is pursuant to a merger of the mortgage originator with another person or the acquisition of the mortgage originator by another person or of another person by the mortgage originator; or (4) the sale, loan, or transfer is to a wholly owned subsidiary of the mortgage originator, provided that, after the sale, assignment, or transfer, the loan is considered to be an asset of the mortgage originator for regulatory accounting purposes

13 My contact info:

AGENCY: Appraisal Subcommittee of the Federal Financial Institutions Examination Council.

AGENCY: Appraisal Subcommittee of the Federal Financial Institutions Examination Council. This document is scheduled to be published in the Federal Register on 05/03/2018 and available online at https://federalregister.gov/d/2018-09419, and on FDsys.gov FEDERAL FINANCIAL INSTITUTIONS EXAMINATION