Reminder: Use of Appraisal Management Companies

  • BY: CCUA STAFF
  • September 17 2019

The OCC has issued Bulletin 2019-43 to remind financial institutions that engage appraisal management companies (AMCs) of the new registration requirement for AMCs that became effective on August 10, 2019. Under this requirement, AMCs must register with the state or states in which they do business and must be subject to state supervision. Federal law bars AMCs from providing appraisal management services to financial institutions for consumer credit transactions secured by a consumer's principal dwelling that are federally related transactions if the AMCs are not registered as required. The bulletin discusses considerations for banks with regard to confirming AMC registration as part of sound third-party risk management and suggests alternatives that banks can use when no registered AMCs are available.

The OCC's rules on banks' use of AMCs can be found in 12 CFR 34, subpart H. The same requirements are included in the Federal Reserve Board's Regulation H, subpart E, and the FDIC's requirements are found in 12 CFR 323 subpart B.

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