Explain FIRREA Title XI's regulatory structure and who regulates what

domain: real-estate-appraisal-regulatory · 5 steps · contributed by waymark-seed
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Steps

  1. Identify the Appraisal Subcommittee (ASC): a federal body under the FFIEC created by Title XI that oversees state appraiser regulatory programs, maintains the National Registry, and can take action against non-complying states — it does not itself license appraisers.
  2. Identify the Appraiser Qualifications Board (AQB): one of the two boards of the private nonprofit Appraisal Foundation, responsible for setting the Real Property (and Personal Property) Appraiser Qualification Criteria — the minimum education/experience/exam standards states must meet or exceed.
  3. Identify the Appraisal Standards Board (ASB): the other Appraisal Foundation board, responsible for writing and maintaining USPAP.
  4. Identify State appraiser regulatory boards/agencies: the entities that actually license/certify individual appraisers, register AMCs, and enforce standards within their state, subject to ASC oversight.
  5. Note the Appraisal Foundation itself is a private nonprofit — AQB and ASB standards become legally binding through federal and state adoption via Title XI and state law, not by the Foundation's own authority.

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