AMC's, USPAP Confidentiality & Graham Leach

[AnonApprsr]

The way I see it is this:

AMC - Contractor

Appraiser - subcontractor

My gf - slave

wait what?

 

[George Hatch]

I've been saying for a long time that some of the activities that occur at the AMCs do fall under the definition of appraisal practice and may come under the jurisdiction of at least some of the state appraisal boards, including California's OREA. I've been told that if the OREA gets a complaint about a Calif. licensee who's working on staff at an AMC performing "appraisal services" as defined in USPAP the OREA will investigate that complaint even if the licensee isn't signing appraisal or review reports.

 

[Mike Kennedy]

68.​

Identification of the Client

69.​

Payment by a Party Other Than the Client

70.​

Difference Between Clients and Intended Users

71.​

Appraisal Management Company as Authorized Agent for a Client

 

[Pamela Crowley (Florida)]

Neither the lenders nor the AMCs want to claim the AMCs are the lender's "agent".

 

[Michael Tipton]

Haven't the AMCs contracted to perform a lending function for the financial institution, their client? Approval of appraisers, "quality control/review" of submitted reports per their client's stated guidelines and payment of appraisal vendors are part of the financial institutions lending operation.

My thoughts are they should be subject to their financial institution client's mortgage lending regulations. Federal banking regulations require USPAP compliant appraisals for transactions requiring an appraisal.