Your appraisal panel crossed a federal threshold and nobody counted it.
An appraisal management company is a business that recruits, selects and retains appraisers and manages appraisal assignments for lenders and secondary market participants. Whether federal minimum requirements apply is decided by a counting exercise: how many state certified or licensed appraisers sit on the panel, in how many states, within a given year. Cross the threshold and registration, ownership and reporting duties follow.
Neurobird Appraisal Management Company AMC in short
- Count certified and licensed appraisers on the panel by state across the relevant year.
- Warn before a threshold is crossed rather than after registration duties have already attached.
- Keep state registrations, renewals and filings against the entity that holds them.
- 15 The statutory panel size threshold is an appraiser panel of more than 15 state certified or state licensed appraisers within a single state. Federal Register final rule
- 25 A separate threshold of 25 or more appraisers applies where a company operates across two or more states in the same period. Federal Register final rule
- Pricing runs 150 to 800 US dollars per month across 3 tiers. Early access is free.
What appraisal management companies and lenders actually deal with
Why it stays broken
Panel management software is built to assign work, not to count people against a statutory test. The test is unusual: it counts certified or licensed appraisers on the panel within a year, and applies different numbers depending on whether the business operates in one state or several. That is a rolling calculation across two dimensions, and an assignment system holds neither.
15 appraisers is the single state panel threshold, with a separate and lower per state figure applying once a company operates across two or more states.
Any appraisal management company doing business in the State of South Dakota is required to be duly registered or cease business until registered.
How does Neurobird Appraisal Management Company AMC work?
Count
Panel members are counted by state and by year on the statutory basis, so the number that matters is always current rather than reconstructed at audit.
Watch
Adding an appraiser in a new state recalculates the multi state position immediately, because that is where the threshold is most easily crossed unnoticed.
File and evidence
Registrations, renewals and registry reporting are held against the entity, so a supervisory question is answered from records rather than recollection.
Neurobird Appraisal Management Company AMC Compliance Platform
Count the panel the way the rule counts it, by state and by year, so threshold crossings are predicted rather than discovered.
- 1Count certified and licensed appraisers on the panel by state across the relevant year.
- 2Warn before a threshold is crossed rather than after registration duties have already attached.
- 3Keep state registrations, renewals and filings against the entity that holds them.
- 4Record what was reported for the national registry and when it was submitted.
What changes with Neurobird Appraisal Management Company AMC?
The same work, read left to right: how it runs today, and how it runs once the record is in one place.
| Today | With Neurobird Appraisal Management Company AMC |
|---|---|
| Panel size is counted informally, so nobody knows which side of the federal threshold the business sits on | Count certified and licensed appraisers on the panel by state across the relevant year. |
| Appraisers are added in a second state and the multi state threshold is crossed without anyone recalculating | Warn before a threshold is crossed rather than after registration duties have already attached. |
| Registration and reporting duties are handled per state with no single record of what was filed and when | Keep state registrations, renewals and filings against the entity that holds them. |
Who is this for?
Three ways a panel quietly becomes a regulated one.
Growth across the state line
A company comfortably below the single state threshold takes work in a neighbouring state. The multi state test uses a different and lower per state count, so a modest expansion can change the regulatory position without the panel feeling any bigger.
Is this even an AMC
The definition turns on providing appraisal management services to creditors or secondary market participants, and specifically excludes performing appraisals. An internal unit needs to know which side of that line it sits on before it needs to know its panel count.
The compliance window
Federally regulated AMCs were given a fixed window from the effective date of the final rule to comply with the minimum requirements. Windows like that are generous until the last month, and they are easy to lose track of across a multi entity group.
What the numbers say about appraisal management companies
The regulatory question is arithmetic before it is anything else. Two counts, measured across a year, decide which regime applies.
The statutory panel size threshold is an appraiser panel of more than 15 state certified or state licensed appraisers within a single state.
Federal Register final ruleA separate threshold of 25 or more appraisers applies where a company operates across two or more states in the same period.
Federal Register final ruleFederally regulated AMCs were required to comply with the minimum requirements no later than 12 months from the effective date of the final rule.
Federal Register final ruleThe minimum requirements for providing appraisal management services sit at 12 CFR 34.215(a), with ownership limitations and registry reporting in the following paragraphs.
Federal Register final ruleSee it work
A short walk through panel counting and a threshold crossing.
| Requirement | Status | Next due | |
|---|---|---|---|
| Threshold near | current | in 42d | |
| Registration filed | due soon | in 9d | |
| Panel counted | current | in 120d | |
| Registration filed | overdue | 3d late | |
| Panel counted | current | in 64d |
Tick a requirement to file evidence against it.
Appraisal management company amc software questions, answered
Key terms
- What is an appraisal management company?
- It is a business that provides appraisal management services to creditors or secondary mortgage market participants. Those services include recruiting, selecting and retaining appraisers and managing the assignment process. Notably the definition does not include performing appraisals, so an appraisal firm doing the valuation work is not automatically an AMC. The distinction matters, because the federal minimum requirements attach to the management activity rather than the valuation itself.
When do the federal minimum requirements apply?
When the panel size threshold is met. The requirements apply to an AMC providing appraisal management services that oversees an appraiser panel of more than 15 state certified or state licensed appraisers in a state, or 25 or more appraisers in two or more states, within a calendar year or twelve month period under state law. Because the count is taken over a year rather than at a moment, a company can meet the threshold without ever having that many appraisers active at once.
Does operating in a second state change anything?
Yes, and this is where companies are most often caught out. The single state test and the multi state test use different numbers, so a modest expansion across a state line can change which threshold applies. A panel that felt comfortably small in one state can sit above the multi state figure once the same appraisers are counted across two.
Can states impose more than the federal minimum?
Yes. States may establish requirements for AMC registration and supervision that are in addition to the federal minimum requirements. That means the federal rule is a floor rather than a ceiling, and a company operating in several states will usually be answering to several overlapping regimes at once.
Is the software available now?
No. It is in development and open for early access. We are building the panel counting and registration record with compliance teams who operate in more than one state.
Why we are building this
The thing that makes AMC compliance awkward is that the trigger is a count, and counts drift.
A panel grows by one appraiser at a time, in states that get added one at a time, and the threshold is measured across a year rather than on a date. By the time anyone asks the question, the answer is historical.
So we are counting the way the rule counts, continuously. The Neurobird Team would rather warn a company before it crosses a line than help it explain why it did not notice.
Where the requirement comes from
Primary sources, straight from the regulators.
- Federal Register, minimum requirements for appraisal management companies The final rule setting AMC definitions, panel thresholds and compliance dates.
- Federal Reserve, requirements for federally regulated AMCs The requirements a federally regulated AMC must meet to provide services.
- FHFA, minimum requirements for appraisal management companies The agency landing page for the same joint final rule.
How much does Neurobird Appraisal Management Company AMC cost?
Early access pricing, held for the first 12 months for teams who help shape the build.
- Panel counting by year
- Threshold warnings
- Registration records
Get free early access
We want compliance officers who have had to work out their panel count retrospectively.
Straight answer on where this is: The software is unfinished. Panel counting, threshold warnings and registration records work. State specific requirements are modelled for a limited number of states.
Prefer email? Write to office@neurobird.com and a person will reply. No autoresponder.