Real Estate Appraiser Bulletin – February 2019

Appraisal Management Company (AMC) Legislation:

Effective April 29, 2019, amendments to Article 6-H of the Executive Law will require Appraisal Management Companies to register with the New York State Department of State.

An Appraisal Management Company is an individual or business entity that provides appraisal management services to creditors or to secondary mortgage market participants, including affiliates, provides such services in connection with valuing a consumer’s real property as security for consumer credit transactions secured by a consumer’s principal dwelling, and within a given year, oversees an appraisal panel of more than 15 appraisers working in New York State or 25 or more appraisers working in two or more states.

A business that hires both appraisers as employees and engages appraisers as independent contractors shall only include the independent contractors during numerical calculation to determine if they meet the definition of an AMC for purposes of state registration.


  • An AMC shall not include a department or division of an entity that provides appraisal management services only to that entity.
  • An individual who hires an appraiser solely for his or her own purposes, shall not be deemed an appraisal management company.
  • An AMC regulated by a federal financial institution regulatory agency is excluded from the registration requirement but is required to report to the Department information required to be submitted to the ASC for the AMC National Registry.

More information regarding the application requirements and process will become available soon.

FHA Appraisers, Home Inspectors & Scope of Practice While Performing FHA-HUD Appraisals:

On September 14, 2015 revised standards were issued by the Federal Housing Administration (FHA) concerning single family appraisals subject to Housing and Urban Development (HUD) regulations. See FHA Single Family Housing Policy Handbook, or Handbook 4000.1

The Handbook requires, among other things, that appraisers operate all conveyed appliances and observe their performance, ensure that electrical receptacles are working and analyze and report all repairs necessary for the subject property to meet HUD's minimum property requirements (MPR) for existing properties or minimum property standards (MPS) for new construction.

Some licensed and certified appraisers within the State of New York have expressed concerns with the Department of State that compliance with the updated HUD regulations would violate state law regarding licensure of home inspection professionals.

As the Department of State regulates and has jurisdiction over both appraisal and home inspection professionals, the agency has reviewed the laws applicable to both practices and does not believe that licensed and certified appraisers violate the standards set forth for home inspectors by complying with the HUD regulations while performing an FHA appraisal.

Appraisers should be aware of these requirements before accepting any FHA appraisal assignment and should not accept any assignment that is beyond the appraiser's ability to perform.

The Role of Supervising Appraisers:

Supervisory Appraisers provide a critical role in the mentoring, training and development of future valuation professionals.

Supervisory Appraisers shall be responsible for the training, guidance and direct supervision of the Trainee Appraiser by:

  • Accepting responsibility for the appraisal by signing and certifying the appraisal complies with USPAP;
  • Reviewing and signing the Trainee Appraiser appraisal report(s); and
  • Personally inspecting each appraised property with the Trainee Appraiser until the Supervisory Appraiser determines the Trainee Appraiser is competent to inspect the property, in accordance with the COMPETENCY RULE of USPAP for the property type.

Supervisory Appraisers must be state-certified, i.e. certified residential or certified general, for a minimum of three years prior to being eligible to become a Supervisory Appraiser.

Supervisory Appraisers shall be in good standing with New York State and not subject to any disciplinary action in any jurisdiction within the last three years that affected the Supervisory Appraiser's legal ability to engage in appraisal practice.

Supervisory Appraisers must comply with the Competency Rule of USPAP for the property type and geographic location where the Trainee Appraiser is being supervised.

Supervisory Appraisers must submit a certificate of completion of the 4-hour Supervisory Appraiser/ Trainee Appraiser Course.

Supervisory Appraisers may not supervise more than three Trainee Appraisers at one time.

Supervisory Appraisers and Appraiser Trainees must maintain a log that includes the following data:

  • Type of property
  • Date of report
  • Address of appraised property
  • Number of actual work hours by the trainee on the assignment
  • Description of work performed by the trainee and scope of the review and supervision of the supervising appraiser, and
  • The signature and state certification number of the supervising appraiser. Separate appraisal logs shall be maintained for each supervising appraiser, if applicable.

Education Update:

You may now complete both qualifying and continuing education courses online. Please visit our list of approved schools that offer the courses here.