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AMC Registration Act

Discussion in 'Illinois' started by Brian Weaver, May 29, 2011.

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  1. form1025

    form1025 Junior Member

    5
    Jul 11, 2009
    Professional Status:
    Certified Residential Appraiser
    State:
    Illinois
    Just for clarification, after the bill has been signed,what amount of time does an amc have to implement any changes and register?
     
  2. ExplainDNA

    ExplainDNA Senior Member

    14
    Oct 30, 2008
    Professional Status:
    Certified Residential Appraiser
    State:
    Illinois
    I'm glad we don't work for AMCs.

    Best,

    Dave...
     
  3. Mike Kennedy

    Mike Kennedy Elite Member

    93
    Sep 28, 2003
    Professional Status:
    Certified Residential Appraiser
    State:
    New York
    Does the Bill present any compliance requirements directed at the Big Box lender-owned AMC subsidiaries exempted from State Registration (Dodd-Frank) that control approx. 80% of mortgage appraisals? :shrug:
     
  4. leelansford

    leelansford Elite Member

    45
    Mar 29, 2002
    Professional Status:
    Certified Residential Appraiser
    State:
    Illinois

    Mike, Sec. 15 of the AMC Law lists the exemptions and the "Big Box lender-owned AMC subsidiaries" are not among these exemptions. As you might guess, there is great interest (at least among appraisers if not the AMCs :)) here in IL in having these AMCs regulated.

    The Law, however, does allow for this single possibility: "In the event that the Final Interim Rule of the federal Dodd-Frank Wall Street Reform and Consumer Protection Act provides that an appraisal management company is a subsidiary owned and controlled by a financial institution regulated by a federal financial institution's regulatory agency and is exempt from the State appraisal management company registration requirements, the Department, shall, by rule, provide for the implementation of such an exemption."

    I was informed by an appraiser (and, member of the IL Coalition of Appraisal Professionals, or, ICAP, legislative committee) who was an active participant in the crafting of the bill that all should be well.

    -Lee
     
  5. ExplainDNA

    ExplainDNA Senior Member

    14
    Oct 30, 2008
    Professional Status:
    Certified Residential Appraiser
    State:
    Illinois
    It's late, and I'd like to speak my mind, but it won't matter, so I won't.

    Best,

    Dave...
     
  6. Brian Weaver

    Brian Weaver Senior Member

    3
    Apr 16, 2005
    Professional Status:
    Gvmt Agency, FNMA, HUD, VA etc.
    State:
    Illinois
    The Governor's staff has 800 bills to consider between now and August. While few are "structural" Acts like our AMC bill, the range of topics is wide. This is why it typically takes so much time to get a bill signed.
     
  7. ExplainDNA

    ExplainDNA Senior Member

    14
    Oct 30, 2008
    Professional Status:
    Certified Residential Appraiser
    State:
    Illinois
    That's naive. There's a much simpler reason than that, Brian. Anyone who understands Illinois will understand what that reason is.

    Dave...
     
  8. Mike Kennedy

    Mike Kennedy Elite Member

    93
    Sep 28, 2003
    Professional Status:
    Certified Residential Appraiser
    State:
    New York
    Thanks Lee, the Contrarian Leprechaun in me urges States to challenge the Exemption below and claim State's Rights supercede arbitrary over-reaching by the Feds craftily designed to protect the status quo to the detriment of their Citizenry.

    ‘‘SEC. 1124. APPRAISAL MANAGEMENT COMPANY MINIMUM REQUIREMENTS.
    ‘‘(a) IN GENERAL.—The Board of Governors of the Federal
    Reserve System, the Comptroller of the Currency, the Federal
    Deposit Insurance Corporation, the National Credit Union Administration
    Board, the Federal Housing Finance Agency, and the Bureau
    of Consumer Financial Protection shall jointly, by rule, establish
    minimum requirements to be applied by a State in the registration
    of appraisal management companies. Such requirements shall
    include a requirement that such companies—
    ‘‘(1) register with and be subject to supervision by a State
    appraiser certifying and licensing agency in each State in which
    such company operates;
    ‘‘(2) verify that only licensed or certified appraisers are
    used for federally related transactions;
    ‘‘(3) require that appraisals coordinated by an appraisal
    management company comply with the Uniform Standards of
    Professional Appraisal Practice; and
    ‘‘(4) require that appraisals are conducted independently
    and free from inappropriate influence and coercion pursuant
    to the appraisal independence standards established under section
    129E of the Truth in Lending Act.
    ‘‘(b) RELATION TO STATE LAW.—Nothing in this section shall
    be construed to prevent States from establishing requirements in
    addition to any rules promulgated under subsection (a).
    ‘‘(c) FEDERALLY REGULATED FINANCIAL INSTITUTIONS.—The
    requirements of subsection (a) shall apply to an appraisal management
    company that is a subsidiary owned and controlled by a
    financial institution and regulated by a Federal financial institution
    regulatory agency. An appraisal management company that is a
    subsidiary owned and controlled by a financial institution regulated
    by a Federal financial institution regulatory agency shall not be
    required to register with a State.

    Dodd-Frank Financial "Reform" Act of 2010
    ( the more things change the more they stay the same - the game continues)
     
    Last edited: Jul 9, 2011
  9. DTB

    DTB Elite Member

    31
    Jun 11, 2004
    Professional Status:
    Certified Residential Appraiser
    State:
    Illinois
    Do I hear envelopes being filled? Nah, couldn't be.
     
  10. Noreen

    Noreen Senior Member

    14
    Feb 5, 2011
    Professional Status:
    Certified Residential Appraiser
    State:
    New Hampshire
    Mike, that is a good point, I know I was under the impression that the reason for licensing within a state is to "quantify" States Rights" within those boundaries.
     
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