Committee Passes H.R. 3619

Committee Passes H.R. 3619 - Requires AMCs to Disclose their FeesH.R. 3619 has passed out of committee and is now sitting in the US House for consideration.

H.R.3619 would amend the Financial Institutions Reform, Recovery, and Enforcement Act of 1989 to provide the Appraisal Subcommittee with the authority to modify annual registry fees for appraisal management companies, to maintain a registry of trainees and charge a lower trainee registry fee, and to allow grants to States to assist appraiser and potential appraiser compliance with the Real Property Appraiser Qualification Criteria and would require AMCs to disclose their fees.

The NCUA Quadrupled The Appraisal Threshold For Nonresidential Real Estate Loans

By a 2-1 vote the board of the National Credit Union Administration (NCUA) voted to raise its appraisal threshold on commercial property from $250,000 to $1 million, twice the level set by the nation’s banking regulators.

An estimated two-thirds of commercial loans by credit unions will now be exempt from the appraisal requirement.

ICAP believes that raising the threshold to such a high level will result in a dramatic loss in appraisal independence and risk mitigation. Optionality for real estate appraisal in commercial lending will result in a return to the loan production-driven environment seen during the lead-up to the financial crisis.

ASC Grants Temporary Waiver of North Dakota Licensing and Certification Requirements

The waiver, which applies to both residential loans below $500,000 and commercial real estate loans below $1,000,000, is for one year with an ASC-activated option for a second year provided that both the Department of Financial Institutions and the Appraiser Board work productively to address issues that lead to some of the longest turnaround times in the nation, whether or not those issues are related to the presence or absence of a scarcity of appraisers in North Dakota.

The grant of a waiver must be concurred in by the Federal Financial Institutions Examination Council and the residential waiver could be sunset 60 days if banking regulators raise the appraisal threshold.

ICAP Board
ICAP Board

ICAP Board

ICAP works to promote the appraisal profession and its image to the general public and to users of appraisal services. ICAP initiates discussion and analysis of issues affecting professional appraisers and monitors political action with the intent to influence legislation, regulation and public opinion toward the appraisal profession.

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4 Responses

  1. Avatar E J says:

    Just another nail in the coffin.

  2. Baggins Baggins says:

    Shall Disclose AMC Fees, that’s very awesome for a national rule. It would have been better to simply separate the fees. Distinctly different services should require distinctly separate fees. For commercial turn down, expect those guys to cut into residential work. Appraisers as a group have substantially less available mortgage lending based potential income potential compared to pre hvcc era.

  3. A little light on reform; the focus is on ASC fee discounts for trainees to attract more cannon fodder for national sweatshop appraisal firms. Grants are for programs to reduce the experience via focused ‘practicum’ courses from what I understand. Please correct if I am wrong on the latter.

    Mandatory disclosure of appraisal fee is a positive thing. Sadly we needed so much more ‘reform’ than this includes.


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Committee Passes H.R. 3619

by ICAP Board time to read: 1 min