A set of commonly asked questions by state appraiser and appraisal management company (AMC) regulatory agencies about how to work with the disruptions arising from the coronavirus (COVID-19) was published recently and provided online by the Federal Financial Institutions Examination Council (FFIEC) Appraisal Subcommittee (ASC), which oversees state appraiser programs.
Some of the questions address the lack of fingerprinting available due to COVID-19 and how that affects appraiser applicants; inability to provide updates to the national Appraiser Registry; timely processing of appraiser applications when board meetings have been canceled; time limits for addressing appraisal complaints; approval for online education (and continuing education) courses; and property inspection requirements.
Regarding fingerprinting, the document notes that fingerprinting for appraiser applicants (and temporary practice applicants) is a state requirement, not federal. “You could consult with your attorney to see if you have the ability to waive or defer this type of background check in lieu of a different type of background check or self-reporting,” it states.
If an agency has trouble updating the Appraiser Registry, the Q&A suggests contacting the assigned ASC policy manager. “ASC IT will help the States keep the Registries updated, including adding information for the State,” it notes.
If an entity cannot timely process appraiser applications due to cancelled board meetings, ASC policy allows for some relief in the face of a state or national emergency as long as the reason is documented, the Q&A explains. (For more on that, see the Q&A.)
The Q&A includes a disclaimer that responses are provided by ASC staff and are not responses from the subcommittee itself.