# Your appraisal panel crossed a federal threshold and nobody counted it.

![A compliance officer checking appraiser panel counts by state against federal thresholds on an office screen, used to show where AMC registration duties are actually triggered.](https://neurobird.com/appraisalcompany/appraisalcompany-hero.webp)
*The trigger is a count taken across a year, not a number on a given day.*

> 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.

- URL: https://neurobird.com/appraisalcompany/
- Product: Neurobird Appraisal Management Company AMC Compliance Platform
- Niche: appraisal management company AMC
- Buyer: appraisal management companies and lenders
- Status: in development, open for early access
- Updated: 2026-08-26

## What Neurobird Appraisal Management Company AMC does

- 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.
- Record what was reported for the national registry and when it was submitted.

## How it works

1. **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.
2. **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.
3. **File and evidence** Registrations, renewals and registry reporting are held against the entity, so a supervisory question is answered from records rather than recollection.

## From the source material

> Any appraisal management company doing business in the State of South Dakota is required to be duly registered or cease business until registered.

Source: dlr.sd.gov, https://dlr.sd.gov/appraisers/information_for_amcs.aspx

## Industry context

- **15** The statutory panel size threshold is an appraiser panel of more than 15 state certified or state licensed appraisers within a single state. (source: Federal Register final rule, https://www.federalregister.gov/documents/2015/06/09/2015-12719/minimum-requirements-for-appraisal-management-companies)
- **25** A separate threshold of 25 or more appraisers applies where a company operates across two or more states in the same period. (source: Federal Register final rule, https://www.federalregister.gov/documents/2015/06/09/2015-12719/minimum-requirements-for-appraisal-management-companies)
- **12 months** Federally regulated AMCs were required to comply with the minimum requirements no later than 12 months from the effective date of the final rule. (source: Federal Register final rule, https://www.federalregister.gov/documents/2015/06/09/2015-12719/minimum-requirements-for-appraisal-management-companies)
- **34.215** The minimum requirements for providing appraisal management services sit at 12 CFR 34.215(a), with ownership limitations and registry reporting in the following paragraphs. (source: Federal Register final rule, https://www.federalregister.gov/documents/2015/06/09/2015-12719/minimum-requirements-for-appraisal-management-companies)

## Pricing

- Single state: $150 per month
- Multi state: $400 per month
- Group: $800 per month

## Questions

### 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.

## Sources

- [Federal Register, minimum requirements for appraisal management companies](https://www.federalregister.gov/documents/2015/06/09/2015-12719/minimum-requirements-for-appraisal-management-companies)
- [Federal Reserve, requirements for federally regulated AMCs](https://www.federalreserve.gov/frrs/regulations/section-225195-requirements-for-federally-regulated-appraisal-management-companies.htm)
- [FHFA, minimum requirements for appraisal management companies](https://www.fhfa.gov/regulation/federal-register/final-rule/minimum-requirements-for-appraisal-management-companies)

## Contact

- office@neurobird.com
- https://neurobird.com/