Letter of Transmittal - Appraisal Subcommittee

Statement 9: Information SharingThe ASC believes that the routine exchange of certain information among lenders, State agencies and theASC is essential to meeting the goals of Title XI.A. National Registry DataIt is critical for State agencies to report expeditiously to the ASC any disciplinary action takenagainst an appraiser. At a minimum, this information must be submitted with the State’s monthly, ormore frequent, Registry data submission. For the most serious disciplinary actions, i.e., suspensions andrevocations, we strongly encourage the State to notify us immediately, and we will update the Registrydatabase. States with Internet e-mail accounts will receive automated notification of all suspensions andrevocations.B. Information Pertaining to Appraiser Conduct and Practices1. State Agency/Lender CommunicationsTitle XI requires “any federally recognized entity,” e.g., a federally regulated institution, to report anyaction of a State certified or licensed appraiser that is contrary to the purposes of Title XI to the appropriateState agency for disposition. In turn, the State agency must provide the ASC with a report regardingthe disposition of such a matter.The ASC believes that full implementation of this Title XI requirement is vital to the integrity of thesystem of State appraiser regulation. By promptly reporting instances of incompetent or unethical behaviorof appraisers to State agencies, State agencies are able to investigate appraiser actions and ensurethat a resulting suspension or revocation of an appraiser’s certificate or license is communicated expeditiouslyto the ASC. At that point, the ASC removes the appraiser’s name and related information fromthe National Registry, thereby preventing the appraiser from legally performing appraisals in connectionwith federally related transactions or for other transactions requiring the use of State certified orlicensed appraisers. As part of its State agency monitoring process, the ASC evaluates the effectivenesswith which each State agency follows up complaints from financial institutions and other persons whoreport instances of appraiser incompetence or unethical behavior.2. Communications Among State AgenciesTitle XI contemplates the reasonably free movement of certified and licensed appraisers across Statelines. This freedom of movement assumes, however, that certified and licensed appraisers are, in allcases, held accountable and responsible for their actions while performing appraisal activities. To ensurethis accountability, State agencies need to establish routine ways to communicate with each other regardingmatters of mutual interest, including the activities and status of persons who are certified orlicensed in multiple States. The ASC Web site provides one such source of information and communication.C. ASC Information “Clearing House” OperationsTo facilitate the development of reciprocity among the States and the creation of State appraisertrainee/apprentice/intern programs, the ASC is developing a database of information that will be48