Check Your Records
Park advises that appraisers regularly review their records in the National Appraiser Registry, located at the ASC website (ASC.gov).  Disciplinary actions, license status- active or inactive, and more are posted publically.  The ASC is a depository of information reported by the various state boards, and although it is rare, it is not without precedent to have inaccurate and potentially damaging information reported there, according to Park. 

AMCs, lenders, insurance companies and others use the Registry to check the status and records of appraisers before doing business with them.

Park also clarifies that the Registry is made up of appraiser credentials and not individual appraisers. Therefore, when you see registry numbers reported, it is important to remember that they reflect the number of active credentials, not the number of individual appraisers, as many appraisers have more than one credential.

Park also notes that the vast majority of appraisers who have exited the profession in the last two years were at the “Licensed Appraiser” level.

Raising the Bar
Appraiser opinions are mixed regarding the recent, more extensive education and training requirements for those entering the profession and wishing to advance. Some feel it enhances the profession to raise the bar, while others caution it will exacerbate the looming “appraiser shortage.” Park indicates that the Appraiser Qualifications Board is looking at various options including working with colleges and universities to bring more young professionals into the business.

Park also notes that the ASC has the authority, with approval of the Federal Financial Institutions Examination Council, to waive any requirement relating to certification or licensing of appraisers, if it or any state agency determines that there is a scarcity of Certified or Licensed appraisers- either in a state or in a particular location, which leads to significant delays in the performance of appraisals.

Lack of Funding for States
The most common problem the ASC sees during its compliance reviews of state appraisal programs is a lack of resources, according to Park. The reason for the lack of funding, in certain states, is that appraiser fees are absorbed into the general funds of those states and used for other purposes. The writers of Dodd-Frank took notice and empowered the ASC to do something about it. The ASC now has the authority to review a state program to determine if there is sufficient funding and to impose sanctions up to and including non-recognition of the state program, if the ASC determines that a state is insufficiently funded to carry out its Title XI requirements.

Park also reminded the audience that the ASC is fully funded by appraiser fees, which totaled just over $2.6 million in 2011, and not taxpayer dollars.  The ASC currently employs a staff of 12.

About the Author
David Brauner is Editor of Working RE magazine and Senior Broker at OREP.org, a leading provider of E&O Insurance for appraisers, inspectors and other real estate professionals in 49 states. He has covered the appraisal profession for over 20 years. He can be contacted at dbrauner@orep.org or (888) 347-5273. Calif. Insurance Lic. #0C89873.