BREA News and Announcements
Customary and Reasonable Fees
BREA has no legal authority to enforce provisions of the Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010 related to Customary and Reasonable Compensation for Fee Appraisers. The Dodd-Frank Act established the Consumer Financial Protection Bureau (CFPB), and many of the pieces of the Dodd-Frank Act relating to the CFPB went into effect on July 21, 2011. For more information, please go to: http://www.consumerfinance.gov/.
Until such time as the CFPB's enforcement authority is fully implemented, violations of Customary and Reasonable Compensation provisions should be reported to:
Board of Governors of the Federal Reserve System
Division of Consumer and Community Affairs
Broker Price Opinions, Value Reconciliation, and other Alternative and Preliminary Valuation Products
Appraiser Independence Requirements from FannieMae and Freddie Mac
- FannieMae Announcement SEL-2010-14 Appraiser Independence Requirements
- FannieMae Appraiser Independence Requirements
- FannieMae Appraiser Independence Requirements FAQs
- Freddie Mac Bulletin 2010-23
- Freddie Mac Appraiser Independence Requirements
- Freddie Mac Appraiser Independence Requirements FAQs
Broker Experience Clarification*
California Code of Regulations, Title 10, section 3541(d) provides that the Bureau of Real Estate Appraisers may issue appraiser licenses (AL designation) to holders of current real estate broker licenses who are able to document 1,000 hours of residential real estate appraisal experience. However, the Appraiser Qualifications Board (AQB) of the Appraisal Foundation requires a minimum 2,000 hours of documented experience for the state license level. Consequently, AL licenses issued with the broker experience credit allowance are not in full compliance with minimum AQB requirements. Because of this discrepancy, the Appraisal Subcommittee classifies such licenses as non-AQB compliant on the National Registry. Some federally regulated lenders may not accept appraisals performed by those licensees. Those licenses, however, can become fully compliant with AQB requirements with a subsequent submission of an appraisal log documenting the necessary hours to achieve the minimum 2,000-hour requirement. AL licensees in this category must submit their additional experience for compliance on the Log of Appraisal Experience REA 3004 form.
* NOTE: Pursuant to the Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010, effective July 1, 2013, BREA will no longer be authorized to issue AL licenses to real estate broker licensees that have not documented the AQB minimum requirement of 2,000 hours of residential real estate appraisal experience. Such licensees will not be listed on the Appraisal Subcommittee's National Registry, and will no longer be eligible to perform appraisals for federally related transactions.
Appraisal Subcommittee's Supplement to Bulletin 2011-01, dated August 11, 2011, regarding Mandatory AQB Criteria for State Licensed Appraisers.
The approval of the Housing and Economic Recovery Act of 2008 mandates revised eligibility requirements for appraisers to qualify for placement and retention on the FHA Appraiser Roster.
No later than October 1, 2009, all FHA Appraiser Roster appraisers in all states and territories must be state certified in order to be eligible to conduct appraisals for FHA-insured mortgages and remain on the FHA Appraiser Roster.