Compliance with Regulation Z

This document offers suggestions as to what forms could be used in an effort to maintain compliance with Regulation Z.

Document 2025  ¦  Last updated:  12/29/2016 MJY

Regulation Z Section 1026.35 expresses that an appraisal is to contain a statement that asserts it was prepared in accordance with FIRREA and any implementing regulations at the time the appraiser signs the appraiser's certification.  This requirement causes confusion because the statement doesn't exist on appraisal forms, and occasionally we are asked whether or not this needs to be added to a la mode's appraisal forms in order for an appraisal to be compliant with Regulation Z.

Many of the major forms are copyrighted by Fannie Mae and because of this, it would require an update on their part in order to add such a statement to the form. Instead, while we can't tell you what you should or shouldn't do to comply with this regulation, we can offer some suggestions as to where this statement could go that would likely be appropriate:

Add the "FIRREA/USPAP Addendum" form
This form is fully customizable and a FIRREA statement made on this form, when placed above the major form, would meet the requirement of disclosing any state‑mandated requirements or USPAP‑related issues.
Add the "USPAP Identification" form
This form has its own signature field and it also includes a customizable field immediately above the signature for you to disclose any state‑mandated requirements or USPAP‑related issues.

Again, the forms listed above are merely suggestions of where a disclosing statement could go.  If you have questions about the usage of these forms or concerns about compliance with Regulation Z, we recommend consulting with other appraisers in your area or contacting your local appraisal and regulatory boards for further assistance.

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