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76 are available but restricted either by regulation or market participants – the very lenders and AMCs creating the demand for the valuation services. Recent articles and presentations on the subject have focused on the number of credentials on the Appraisal Subcommittee (ASC) National Registry and the message conveyed is that the number of appraisers is actually increasing. However, a point of clarification seems to be in order. e ASC National Registry contains appraiser credentials for state licensed and certified appraisers. It does not contain data on the number of trainees. It also reflects the number of credentials, not individuals. Nor does it reflect how many appraisers are actually providing appraisal services instead of working in an internal administrative, managerial, supervisory role or acting in an in-house review capacity and not actually completing appraisals. We are currently working on an answer of how many appraisers are actually completing appraisal assignments nationwide for mortgage lenders. Until we have those results, a deeper dive into the data on the ASC National Registry will provide a bit more clarity. e ASC National Registry contains data on licensed and certified credentials. To drill down to the number of appraisers, a snapshot of the ASC National registry as of April 12, 2016 revealed the following: 97,334 = Total Number of Credentials 73,541 = Number of Appraisers Licensed / Certified in one state 8,996 = Number of Appraisers Licensed / Certified in more than one state 23,803 = Number of credentials represented on the National Registry by the 8,996 appraisers 17,119 = Difference in total credentials vs. individual appraisers. In response to state licensing requirements and concerns over reputational risks, a growing number of chief appraisers and AMC senior management indicate they are requiring their staff reviewers to be licensed in multiple states, which would suggest the number of credentials on the ASC National Registry is not a reflection of additional appraisers, but rather a reflection of the increase in the number of appraisers obtaining multiple state credentials. As mentioned earlier, when we analyze the number of licensed and certified appraisers available to complete assignments for mortgage lending transactions we also have to take into account the number of certified appraisers working in administrative, management, internal review roles and as such, do not complete appraisal assignments. A polling of members attending the CRN Conference in New Orleans revealed that a majority were in administrative / management positions and had not been completing appraisal assignments for several years. HOW DOES THE FUTURE LOOK? At a recent AARO (Association of Appraiser Regulatory Officials) conference in Phoenix, Arizona, Jim Park, Executive Director of the Appraisal Subcommittee indicated that the ASC data shows approximately 8,000 to 9,000 trainees nationwide. What follows next are the results of a March 2016 survey of the state appraiser regulatory agencies conducted by asking for data relating to the trending of appraiser trainees. Whether looking at the rate of application, renewal, or the actual number of trainee credentials, the survey results received from the state regulatory agencies confirm the concerns the National Appraisal Congress, the Collateral Risk Network, and the National Association of Appraisers have been expressing relating to the potential appraiser shortage that will be facing the industry unless significant and immediate changes occur within the regulations governing entry into the profession and the acceptability of trainees and licensed appraisers by lenders and appraisal management companies. Regardless of one's position on whether there is a current shortage of appraisers to complete mortgage lending assignments, the data presents a sobering reality that if the trend continues, the appraisal industry will not be able to respond to an increase in market demand for appraisal services within a very few short years as the number of appraisers continue to leave the industry and the number of potential replacements is declining at an even greater pace. ECONOMIC CHALLENGES FACING STATE LICENSED APPRAISERS When Congress mandated that HUD only accept appraisers with certified credentials for the FHA panel, it was the beginning of the end for licensed appraisers. Not only are they excluded from FHA assignments, most lenders "When Congress mandated that HUD only accept appraisers with certified credentials for the FHA panel, it was the beginning of the end for licensed appraisers."

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