National Registry for Appraisal Management Companies on the Horizon

Alston & Bird
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On May 20, 2016, the Appraisal Subcommittee of the Federal Financial Institutions Examination Council (ASC) issued a proposed rule to implement collection and transmission of the appraisal management company (AMC) annual national registry fee. The AMC National Registry will be a database maintained by the ASC containing certain information about state-licensed or registered AMCs and federally regulated AMCs as mandated by the Dodd-Frank Wall Street Reform and Consumer Protection Act. The AMC registry fee will impose a financial burden on AMCs, but how this fee could impact appraisers and the cost of appraisals is not yet clear. Although $25 per appraiser may seem like a nominal fee, for an AMC with thousands of appraisers on its panels, the annual AMC registry fee may pose a significant financial burden. The proposed rule does not specify the timing of the AMC National Registry but rather indicates that the ASC will issue a bulletin prior to the effective date of the final rule addressing when the AMC National Registry will be open for states and the information that states will have to report to the ASC. Comments to the ASC’s proposed rule are due by July 19, 2016.

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DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

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