Which registries does the Appraisal Subcommittee maintain?
Correct Answer
D) The National Registry of Appraisers and the National Registry of Appraisal Management Companies
The ASC maintains both the Appraiser Registry and the AMC Registry under its statutory responsibilities. Registry listing and reporting operate within the applicable state and federal framework; the ASC is not the state agency issuing each individual appraiser credential. Do not infer that AMC oversight means the ASC has no AMC registry.
Why This Is the Correct Answer
Option D is correct because the ASC maintains the National Registry of Appraisers and the National Registry of Appraisal Management Companies. Federal law directs state programs to report complaints and disciplinary actions to the national registries on appraisers and AMCs maintained by the ASC. The ASC keeps these registries but is not the state agency that issues each individual credential.
Why the Other Options Are Wrong
Option A: A registry of individual property transactions reported by state agencies
Option A, a registry of individual property transactions reported by state agencies, is wrong because the ASC registries list appraisers and AMCs, not property sales or transactions.
Option B: A national register of all mortgage loan applicants and their credit files
Option B, a national register of mortgage loan applicants and their credit files, is wrong because the ASC does not track borrowers or credit files; its registries cover appraisers and appraisal management companies.
Option C: A registry of education instructors and course providers, with no appraiser or AMC registry
Option C is wrong because it claims the ASC keeps only an instructor and course-provider registry with no appraiser or AMC registry. The ASC does maintain both an appraiser registry and an AMC registry, and overseeing AMC programs does not mean it lacks an AMC registry.
Two registries, two A's
The ASC keeps two lists that both start with A: Appraisers and AMCs. If an option mentions borrowers, sales or instructors, it is not an ASC registry.
How to use: Use this when a question asks what the ASC maintains, and look for the option naming both appraisers and AMCs.
Exam Tip
Separate the roles: the ASC monitors and keeps national registries, states issue credentials and register AMCs, and The Appraisal Foundation sets standards and qualification criteria.
Common Mistakes to Avoid
- -Assuming the ASC issues appraiser licenses rather than the state agencies
- -Thinking the ASC has no AMC registry because states register AMCs
- -Confusing the ASC with The Appraisal Foundation or its boards
Concept Deep Dive
Analysis
This question tests whether you know which national registries the Appraisal Subcommittee (ASC) keeps under federal law. Title XI refers to national registries on appraisers and on appraisal management companies maintained by the ASC, and states report complaints and disciplinary actions to them. Pick the option that names both registries and reject options describing transaction, borrower or instructor databases.
Background Knowledge
The Appraisal Subcommittee was created under Title XI of FIRREA to monitor state appraiser regulatory programs, and later amendments to Title XI added oversight of state AMC programs. Part of its role is keeping national registries that list credentialed appraisers and registered AMCs, which states supply with credential and disciplinary information.
Real-World Application
A lender's vendor manager wants to confirm that an out-of-area appraiser holds an active credential before assigning an order. She searches the ASC's National Registry of Appraisers and also checks that the AMC handling the order appears on the AMC registry.
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