You can read your states laws and rules and make the determination for yourself. It is your responsibility to follow all state laws. I would wait until the NCAB issues a memo on them before I even considered doing one. Perhaps they read the laws and rules differently that I do - it wouldn't shock me if they did. Like most boards, they are scared to death of AMC's it seems. I would expect them to put the burden and responsibility 100% on the backs of appraisers, like they always do. I wouldn't want to defend the position that I had direct supervision over all parties that provided data for the sole purpose of inclusion in my report. Maybe it can be defended, who knows?
(my bold)
That's a sad statement of your board's composition.
I do note that you qualify your statement by saying "...most boards" and "... it seems". I appreciate that qualification.
I don't have experience with judging all boards on an objective basis. I will say this...
The Illinois board seems less than accommodating to AMCs. So much so, that they've been very aggressive in their licensing enforcement and have had to (if memory serves), walk back some of their enforcement action (or, maybe it was only one enforcement action).
Louisiana, who has successfully enforced one case of C&R by an AMC, doesn't seem to fear them at all.
I've heard (so this is anecdotal) Montana is near anti-AMC.
I'd say my own state (California) has no fear of pursing a complaint against an AMC.
Are there boards that do fear AMCs? I cannot say there isn't, and will accept that there may well be.
What I do believe is that there is a wide range of expectations of appraisers what AMC regulations are, and how they can be effectively enforced.
That's why I advocate for appraisers to join organizations that can lobby their regulators (and legislators) to align the enforcement rules/regulations with what the appraisers want to achieve.
Naturally, I may disagree with the objective. But I'll never disagree with the concept of organization and petition for an objective is a waste of time.
If I recall correctly, you do participate in appraisal organizations. Hopefully, others that agree with you will follow suit.