UPDATED: Appraisal management company registry plan sent to OMB, out for comment one more time

The federal panel responsible for oversight of states’ real estate appraiser regulatory programs will accept comments until June 14 on the information it plans to collect for a national registry of appraisal management companies (AMCs), according to a notice in the Federal Register.

The panel, the Federal Financial Institutions Examination Council (FFIEC) Appraisal Subcommittee (ASC), sought comments on the proposed information collection this January, but it said the four comments received addressed only “irrelevant subject matter.” This notice allows additional comments while the subcommittee awaits final review and clearance by the Office of Management and Budget (OMB).

July 16 is the date the registry is supposed to open to the states, according to an ASC announcement last month.

The ASC is required by the Dodd-Frank Wall Street Reform and Consumer Protection Act (Dodd-Frank) to maintain a national registry of AMCs that are either: (1) registered with and subject to supervision by a state that has elected to register and supervise AMCs; or (2) are operating subsidiaries of a federally regulated financial institution (federally regulated AMCs). States that will be listing AMCs on the registry, according the the notice for comment, will be required to provide the following data on the companies:

  • state abbreviation
  • state registration number for the AMC
  • employer identification number (EIN)
  • AMC name, street address, city, state and zip
  • license or registration status – effective date and expiration date
  • AMC type (state or multi-state)
  • disciplinary action – effective date and expiration date
  • number of appraisers (for invoicing registry fee)

The above data is based on minimum requirements set under the Dodd-Frank Act by federal financial institution regulators, the Consumer Financial Protection Bureau (now the Bureau of Consumer Financial Protection, or BCFP) and Federal Housing Finance Agency (which regulates Fannie Mae, Freddie Mac and the Federal Home Loan Banks).

States listing AMCs on the AMC Registry will enter the above information for each AMC for the initial entry only, the notice says. After the initial entry, the information will be retained on the AMC Registry, amended only if necessary by the state.

Comments continue to be invited on:

(a) Whether the collection of information is necessary for the proper performance of the functions of the agency, including whether the information shall have practical utility;

(b) The accuracy of the agency’s estimate of the burden of the collection of information;

(c) Ways to enhance the quality, utility, and clarity of the information to be collected;

(d) Ways to minimize the burden of the collection on respondents, including through the use of automated collection techniques or other forms of information technology; and

(e) Estimates of capital or start-up costs and costs of operation, maintenance, and purchase of services to provide information.

The subcommittee estimates each entry to the ASC will take the submitter about 15 minutes. The overall burden estimate assumes all 50 states will participate and an average of 150 AMCs in each state.

FFIEC Appraisal Subcommittee information collection: Reporting information for the AMC Registry