On May 31, 2017, the federal bank regulatory agencies - the Board of Governors of the Federal Reserve System, the Federal Deposit Insurance Corporation (FDIC), the National Credit Union Administration (NCUA), and the Office of the Comptroller of the Currency (OCC) – released an Issue Advisory on Appraiser Availability drawing attention to two existing options a state may use when facing a shortage of appraisers.
(1) Allowing out-of-state qualified appraisers to temporarily practice in an underserved area. These permits allow appraisers credentialed in one state to provide their services on a temporary basis in another state experiencing a shortage of appraisers, subject to state law. States can also consider offering reciprocity to appraisers in another state, by allowing appraisers that are certified or licensed in another state to obtain certification or licensing without having to meet all of the state's certification or licensing standards.
(2) Ask the Appraisal Subcommittee (ASC) to issue temporary waivers to any appraiser qualification requirement for individuals. These waivers set aside requirements relating to the certification or licensing of individuals to perform appraisals in Federally Related Transactions (FRT) under Title XI of the Financial Institutions Reform, Recovery, and Enforcement Act of 1989 (FIRREA) in states where certain conditions are met. These waivers may be given if it is determined that there is a scarcity of state-certified or -licensed appraisers leading to significant delays in obtaining an appraisal.
The reason for the Advisory stems from the ongoing concern in many areas, particularly in rural areas, that there is a perceived shortage of appraisers. These are not new policies for dealing with appraisal delays, but are being highlighted given increased wait times for appraisals in rural areas.