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Final Rule Released on Minimum AMC Requirements

April 22, 2015 12:30 PM

The Federal Deposit Insurance Corporation, the Federal Housing Finance Agency, the Consumer Financial Protection Bureau the Federal Reserve and the Office of the Comptroller of the Currency released on April 21 its final rule on minimum requirements for state registration and supervision of appraisal management companies, as required by the Dodd-Frank Act.

States will have 36 months from the release of the rule to set up AMC registration and supervision systems.

Highlights of the rule include:

Independent Contractor Definition: The rule revises the standard used to determine if an appraiser is an independent contractor based on whether or not the appraiser is treated as an independent contractor by the AMC for federal income tax purposes.

AMC/Appraisal Firm Distinction:The rule distinguishes between AMCs and appraisal firms based on their respective use of fee appraisers and employees. Each employee appraiser must pay a registration fee to the state or states where they practice. An AMC will only be subject to a registration fee once state registration and supervision regulations become effective pursuant to Dodd-Frank. The rule also provides coverage for “hybrid” firms, meaning entities that both hire appraisers as employees to perform appraisals and engage independent contractors to perform appraisals.

AMC Panel Threshold Size:The rule clarifies that when the number of appraisers is counted for the purpose of determining the size of an AMC’s panel threshold, that the count be based on the number of appraisers listed on the roster who potentially are available to perform appraisals and not on the number of appraisers actually engaged to perform appraisals.

Trainee Appraisers Not Barred:The rule clarifies that AMCs may engage appraisers who use trainee appraisers to assist on assignments.  

View a copy of the final rule for Minimum Requirements for Appraisal Management Companies.

View a copy of the Appraisal Institute’s comment letterto the federal agencies on their proposed rule addressing “Minimum Requirements for Appraisal Management Companies.” (log-in required).


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The Appraisal Institute is a global professional association of real estate appraisers, with nearly 21,000 professionals in almost 60 countries throughout the world. Its mission is to advance professionalism and ethics, global standards, methodologies, and practices through the professional development of property economics worldwide. Organized in 1932, the Appraisal Institute advocates equal opportunity and nondiscrimination in the appraisal profession and conducts its activities in accordance with applicable federal, state and local laws. Individuals of the Appraisal Institute benefit from an array of professional education and advocacy programs, and may hold the prestigious MAI, SRPA, SRA, AI-GRS and AI-RRS designations. Learn more at




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