Written By: Stacey Sprain, Op-Ed Writer
I’ve already had questions on this issue come up a number of times in the past 24 hours so I figured would be a great topic of discussion for this week.
HUD issued Mortgagee Letter 2008-39 back on December 17th of 2008 covering the subject of Eligibility Requirements for FHA Roster Appraisers effective on and after October 1st of 2008 and on October 1st of 2009.
To meet the new eligibility requirement that takes effect for cases requested on and after October 1st, FHA appraisers must be certified by the state in which the property to be appraised is located, or by a nationally recognized professional organization. Such recognized organizations include the American Society of Appraisers, the American Society of Farm Managers and Rural Appraisers, the Appraisal Institute, the Appraisers Association of America, the International Association of Assessing Officers, the International Right of Way Association, the Massachusetts Board of Real Estate Appraisers, the National Association of Independent Fee Appraisers, and the National Association of Master Appraisers. Links to each website, which includes search capabilities, can be found by accessinghttp://www.appraisalfoundation.org/s_appraisal/sec.asp?CID=15&DID=15.
In order for an appraiser to be eligible as a new FHA Roster applicant or for reinstatement, the appraiser must be a state-certified appraiser with credentials based on the minimum certification criteria issued by the Appraiser Qualifications Board (AQB) of the Appraisal Foundation, and must not be listed on GSA's Excluded Parties List System (EPLS), HUD's Limited Denial of Participation (LDP) list, or HUD's Credit Alert System (CAIVRS). Appraisers should refer to the FHA Roster Appraiser Page at http://www.hud.gov/groups/appraisers.cfm for additional information on qualifying as an FHA Roster Appraiser.
If, on or after October 1, 2009, an FHA-approved lender enters an appraisal assignment into FHA Connection for a property from a FHA Roster Appraiser who is licensed but not certified in accordance with the Mortgagee Letter, the appraisal will be unacceptable for FHA-insured financing and a second appraisal, performed by a state certified appraiser, must be completed at the lender’s expense.
Need FHA Training? CLICK HERE: http://www.FHA-Classes.org
I am hearing that HUD may not be completely up to date by October 1st so that it will fall to lender responsibility to ensure that any FHA appraiser used for cases assigned on and after October 1st meets the minimum requirements. That being said as worst case scenario, the question becomes- “How do I determine whether or not a particular FHA appraiser is certified to meet the requirements of the Mortgagee Letter?”
To answer that question, I refer to The ASC Appraisal Subcommittee website which hosts the national appraiser registry. The National Registry is a database containing selected information about the Nation's State certified and licensed real estate appraisers. The National Registry does NOT contain information on ALL appraisers. It only contains information about appraisers who currently are, or have been, certified or licensed by a U.S. State, Territory or possession to perform appraisals in connection with Federally-related real estate transactions (which includes FHA appraisals).
Only State certified or licensed appraisers who are listed on this National Registry as having currently valid certifications or licenses are authorized under Federal law to perform appraisals in connection with federally related transactions. Note that expiration dates on actual certificates or licensing documents may differ from expiration dates listed in the National Registry. National Registry expiration dates specifically relate to the legal authority of certified or licensed appraisers to perform appraisals in connection with federally related transactions.
It’s very simple to utilize the query options available athttps://www.asc.gov/default.aspx?id=11. Here you can choose to look up an appraiser by city, county, state or actual individual name in order to determine his or her current status. You will want to utilize options 3 or 4 to search for FHA-eligible appraisers. Query option number 3 allows you to pull a query of certified general appraisers by city or county and option number 4 allows you to pull a query of certified residential appraisers by city or county. The query list will list appraisers by last name, first name, will list the license state, license number, the current active or inactive status and will indicate Yes, no or Unknown as an answer to “Meets AQB.” For FHA appraiser eligibility, the status must reflect Active and the query must indicate “Yes” under Meets AQB.
As of October 1st, if an appraiser isn’t listed on the national registry, he/she is not eligible to conduct appraisals for FHA or any other federally related mortgage transaction.
I highly recommend pulling together a list of your most commonly used FHA appraisers and conducting queries at the ASW website to determine if they are listed and reflecting proper statuses. If they are not listed now, think worst case that they may not be listed by October 1st and take immediate action to notify them of their need to comply with the requirements of HUD’s Mortgagee Letter 2008-39 and refer them directly to the FHA Appraiser Roster web page athttp://www.hud.gov/groups/appraisers.cfm.
In reading and researching to obtain the information I’m sharing with you in the above article, I ran across the following which you may wish to read through or participate in to expand your FHA appraiser/appraisal knowledge as well.
Need FHA Training? CLICK HERE: http://www.FHA-Classes.org
About The Author
Stacey Sprain - As an op-ed writer, Ms. Stacey Sprain is currently a NAMP® Certified Ambassador Loan Processor (NAMP®-CALP). With over 15+ years of mortgage banking experience, Stacey is also a Quality Control Manager for a major mortgage lending institution.