4000 - Advisory Opinions
Whether Appraisal-Type Functions May Be Performed by Uncertified and Unlicensed Appraisers Under USPAP Standards and 12 C.F.R. § 323.5(b)
FDIC 91-46 May 23, 1991 Walter P. Doyle, Counsel
Thank you for your recent letter regarding use of the term "review appraiser."
As you know, USPAP standards were written prior to enactment of appraiser certification and licensing requirements in Title XI of FIRREA. Consequently the term "appraiser" in USPAP describes a generic function of which certified and licensed appraisers are a subset. Thus, the use of the term "appraiser" or "review appraiser" in USPAP does not necessarily exclude reference to "appraisers" who are not certified or licensed. There certainly are appraisal functions, even after adoption of Title XI and the agency regulations, that do not require certification or licensing. Indeed, the review procedure described in the second sentence of § 323.5(b) of our regulation does not mandate the use of certified or licensed appraisers for conducting the review contemplated therein.
In sum, there does remain a number of conceivable appraisal-type functions that still may be legally performed by uncertified and unlicensed persons so long as regulated institutions comply scrupulously with applicable statutory and regulatory requirements.
I trust this has been responsive to your letter.