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
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.
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.
Identify the Appraisal Standards Board (ASB): the other Appraisal Foundation board, responsible for writing and maintaining USPAP.
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.
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.
Known gotchas
The Appraisal Foundation, AQB, and ASB are private-sector bodies, not government agencies — their standards carry legal weight only because Title XI and state law incorporate them.
The ASC monitors and can sanction states, but does not itself issue or revoke individual appraiser credentials — that authority sits with the state boards.
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