The Appraisal Subcommittee is a subcommittee of which body?
Correct Answer
C) Federal Financial Institutions Examination Council
Title XI established the Appraisal Subcommittee of the Federal Financial Institutions Examination Council. The ASC has its own statutory appraisal-regulatory mission, including monitoring state programs and maintaining registries. The affiliation alone should not be expanded into unsupported claims that another single member agency controls every ASC operation or that its budget and staffing are simply FFIEC resources.
Why This Is the Correct Answer
Option C is correct because Title XI established the Appraisal Subcommittee as a subcommittee of the Federal Financial Institutions Examination Council (FFIEC). Federal rules refer to the National Registry as maintained by the Appraisal Subcommittee of the Federal Financial Institutions Examination Council. The ASC carries its own appraisal regulatory mission, such as monitoring state programs and maintaining registries.
Why the Other Options Are Wrong
Option A: Office of the Comptroller of the Currency’s board
Option A names the Office of the Comptroller of the Currency's board. The ASC is a subcommittee of the FFIEC, not of any single member agency such as the OCC.
Option B: Consumer Financial Protection Bureau
Option B names the Consumer Financial Protection Bureau. The ASC is formally part of the FFIEC, not a subcommittee of the CFPB.
Option D: A state appraiser licensing board
Option D names a state appraiser licensing board. The ASC is a federal body that monitors state appraiser programs; it is not a subcommittee of any state board.
ASC lives inside FFIEC
Think of the ASC as a smaller room inside the FFIEC building: the subcommittee sits within the examination council, and it watches over the state programs.
How to use: Use this picture when asked where the Appraisal Subcommittee sits in the federal structure.
Exam Tip
When a question asks which body the ASC belongs to, look for the Federal Financial Institutions Examination Council by name. Single agencies and state boards are common distractors.
Common Mistakes to Avoid
- -Assuming the ASC belongs to one member agency such as the OCC
- -Confusing the ASC with the Consumer Financial Protection Bureau
- -Thinking the ASC is a state-level licensing body
Concept Deep Dive
Analysis
This question tests knowledge of the federal appraisal regulatory structure created by FIRREA Title XI. The key fact is the formal name of the body: the Appraisal Subcommittee of the Federal Financial Institutions Examination Council. Recognizing that full name lets you pick the answer and rule out single agencies and state boards.
Background Knowledge
FIRREA Title XI set up the federal framework for appraiser regulation. The Appraisal Subcommittee of the FFIEC monitors state appraiser certification and licensing programs and maintains the National Registry of state certified and licensed appraisers.
Real-World Application
A lender verifies that an appraiser holds an active certification by checking the National Registry. That registry is maintained by the Appraisal Subcommittee of the FFIEC, which collects data on state certified and licensed appraisers.
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