May 19, 2017 – I was notified this week that Illinois has had a law on their books that allows licensed appraisers to perform non-USPAP Evaluations. I have no clue how long it has been there. Maybe someone from Illinois knows and can tell me. So, we are actually at 5 states now, albeit Virginia has a technical glitch that will delay the law for a year. Following is an excerpt from the law (I will add emphasis to the key words) and additional explanation I have received from my ‘sources.’ (oh geez I sound like the Fake News Media!)
225 ILCS 458/5-5a – “It is unlawful for a person to …. (ii) develop a
real estate appraisal, (iii) practice as a real estate appraiser… without a license issued under this Act.”
225 ILCS 458/5-5g – “This act does not apply to”….
 an employee, officer, director, or member of a credit or loan
committee of a financial institution or any other person engaged by a financial institution when performing an evaluation of real property for the sole use of the financial institution in a transaction for which the financial institution would not be required to use the services of a State licensed or State certified appraiser pursuant to federal regulations adopted under Title XI of the federal Financial Institutions Reform, Recovery, and Enforcement Act of 1989… (emphasis added)
The state board has confirmed to several people that state-certified appraisers are permitted to perform non-USPAP compliant evaluations when engaged by an institution. The only caveat is that the appraiser cannot sign as an appraiser, reference their state credential or any appraisal related designations.