COUNCIL OF THE DISTRICT OF COLUMBIA

COMMITTEE OF THE WHOLE

1350 Pennsylvania Avenue, NW

Washington, DC 20004

 

MEMORANDUM

 

TO:                       Nyasha Smith, Secretary to the Council

               

FROM:               Phil Mendelson, Chairman

                                                               

DATE:                July 3, 2019

 

RE:                       Request to Place Emergency Measures on the Agenda for the July 9, 2019 Legislative Meeting

 

            Please place the following measures on the agenda for the July 9, 2019 Additional Legislative Meeting:

 

• Appraisal Management Company Regulation Emergency Act of 2019
• Appraisal Management Company Regulation Emergency Declaration Resolution of 2019

 

            The purpose of the emergency legislation is to enact minimum licensing and regulatory requirements for appraisal management companies pursuant to federal law (12 U.S.C. § 3353) and federal regulations (12 CFR § 34.210 et seq.; 12 CFR 208.50 and 225.190 et seq.; 12 CFR 323.8 et seq.; 12 CFR 1222.20 et seq.).

 

            The Dodd-Frank Wall Street Reform and Consumer Protection Act (the Dodd-Frank Act) required federal agencies to establish minimum standards applied by states in the registration of appraisal management companies. States were granted 36 after the date on which the regulations were promulgated to adopt minimum requirements in the registration of appraisal management companies, with the opportunity to request a 12-month extension. The draft emergency legislation would adopt said minimum requirements.

           

            Federal agencies issued final rules in compliance with the Dodd-Frank Act on August 10, 2015, for an initial deadline of August 10, 2018. The District of Columbia requested and was granted a one-year extension. Only DC and Massachusetts have not adopted the requirements. If law and regulations are not in place by August 10, 2019  – if this emergency legislation is not adopted – appraisal management companies will not be able to facilitate Federally Related Transactions. This could lead to higher appraisal costs for consumers, adoption of burdensome contingency plans by lenders to avoid Federally Related Transactions, and a loss of revenue for appraisal management companies.