Background checks

[Meandering]

Who suggested it?

I believe it came from the ivory tower joint commission of BS, and was a requirement for vendors of lenders, meaning owners of AMCs, not vendors of 3rd parties. I know JT and I fought about the wording a year or more ago. It'll take me some time to look up the exact name of the ivory tower commission and the regulation they issued, but I'll search for it if you need it. Otherwise, for the state to do it, I believe came from the Interim Final Rule of the Fed Board. But that's off the top of my head.

 

[Meandering]

Marion, do you know if it the ASC that first suggested background checks on appraisers or did it come down the line from elsewhere.

Here is an official response.
https://icapweb.wordpress.com/2013/12/03/aaro-fall-conference-the-second-in-a-three-part-series/