The Office of the Controller of the Currency (OCC) outlines the management responsibility banks must take when dealing with third parties. Third parties include the banks AMCs use to manage their appraisal orders, and vendor appraisers
Many AMCs are taking the position that their panel appraisers must have a background check to be sure the appraiser is in compliance. The difficulty for appraisers is related to the acceptance of background checks. Most AMCs have taken the position that the appraiser must provide a background check through the AMC’s selected contractor who does the background check.
If an appraiser works for multiple AMCs, that can mean multiple background checks, adding time and expense to the appraiser’s workload. The other factor is that most states currently do not do background checks for renewing appraisers, and in some cases, currently don’t do them for new appraiser license applicants, according to AppraiserBlogs.
That will change in 2017 when the Appraiser Qualifications Board (AQB) has mandated that all new applicants must have background checks done by the state as part of the application process. The requirement originally was supposed to take effect in 2015, but the AQB pushed the effective date back two years to allow states to prepare for the change. The AQB policy does not address license renewals by existing appraisers. Individual states will decide what to do for those.