NAR Wrote the Appraisal Subcommittee Regarding the Effectiveness of State Appraiser and Appraisal Management Company Regulatory Programs

On February 4, 2025, NAR issued a comment letter to the Appraisal Subcommittee (ASC) in response to a proposed rule on the "ASC Enforcement Authority Regarding the Effectiveness of State Appraiser and Appraisal Management Company (AMC) Regulatory Programs."  

NAR policy supports independent valuations of real property performed by state credentialed appraisers in adherence with the Uniform Standards of Professional Appraisal Practice (USPAP); therefore, it is crucial that effective oversight of both appraisers and the appraisal management companies is in place and exercised. While the proposed rule codifies ways the states should oversee appraisers, it omits specific language on AMC monitoring and ways to report AMC violations.

This comment letter suggests additional monitoring, adding whistleblower protection, promoting consistency in regulation and investigation, monitoring adequacy of jurisdictions’ funding, and measurement of how effectively new rules and oversight affect compliance.

Read the comment letter to the ASC.

Read the ASC proposed rule.