Question: If a lender utilizes an Appraisal Management Company (AMC) for the selection of an appraiser, is the lender still responsible for ensuring the appraiser holds an active state license or certification?
Yes. Lenders must ensure the state license or certification is active as of the date of the appraisal. The alignment with an AMC does not absolve the lender of the responsibility of ensuring that the AMC, a vendor and service provider, is operating within the confines of the lender’s vendor management policies.
Whether you instruct the processors and underwriters to check the status of the appraisers on a loan level basis or you institute a master list of appraisers with their respective license or certification expiration dates, this re-certification is required.
The lender should review the AMC annually, the requirements for which would be in the vendor management policy. More information about vendor compliance is available at our affiliate Web site, Vendors Compliance Group
Brandy George is director of Underwriting Operations Compliance and executive director of LCG Quality Control.