Title XI of FIRREA created which body to monitor state appraiser certifying and licensing programs?
Correct Answer
D) The Appraisal Subcommittee of the FFIEC
Title XI of FIRREA (1989) established the Appraisal Subcommittee (ASC) of the Federal Financial Institutions Examination Council to monitor state appraiser programs, maintain the National Registry and oversee the Appraisal Foundation's Title XI activities. The ASB and AQB are boards of the private Appraisal Foundation that set USPAP and qualification criteria. The CFPB was created by Dodd-Frank in 2010.
Why This Is the Correct Answer
Option D is correct because Title XI of FIRREA (1989) established the Appraisal Subcommittee of the FFIEC to monitor state appraiser programs. The ASC also maintains the National Registry and oversees the Appraisal Foundation's Title XI activities.
Why the Other Options Are Wrong
Option A: The Appraisal Standards Board
Option A names the Appraisal Standards Board. The ASB is a board of the private Appraisal Foundation that sets USPAP; it does not monitor state licensing and certification programs.
Option B: The Appraiser Qualifications Board
Option B names the Appraiser Qualifications Board. The AQB is a board of the Appraisal Foundation that sets appraiser qualification criteria, not the federal body that monitors state programs.
Option C: The Consumer Financial Protection Bureau
Option C names the Consumer Financial Protection Bureau. The CFPB was created by Dodd-Frank in 2010, not by Title XI of FIRREA, and it is not the body that monitors state appraiser programs.
ASC watches the states
The ASB writes standards, the AQB writes qualifications, and the ASC watches how states run their programs.
How to use: Use this to match each appraisal body to its role.
Exam Tip
Separate the private Appraisal Foundation boards from the federal Appraisal Subcommittee when a question asks about monitoring state programs.
Common Mistakes to Avoid
- -Confusing the Appraisal Subcommittee with the Appraisal Standards Board
- -Thinking the AQB oversees state licensing programs
- -Attributing the CFPB to FIRREA
Concept Deep Dive
Analysis
This question tests knowledge of the regulatory structure created by Title XI of FIRREA. The Appraisal Subcommittee of the Federal Financial Institutions Examination Council monitors state appraiser certifying and licensing programs. Distinguishing the federal oversight body from the private Appraisal Foundation boards is the key.
Background Knowledge
Title XI of FIRREA created a framework in which states license and certify appraisers, the Appraisal Foundation's boards set standards and qualification criteria, and the Appraisal Subcommittee provides federal oversight. The ASC monitors state programs and maintains the National Registry of appraisers. This structure separates standard setting from federal monitoring.
Real-World Application
An appraiser checks the National Registry to confirm that a colleague holds a valid credential in another state. That registry is maintained by the Appraisal Subcommittee, which also reviews how state appraiser boards operate.
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