Friday, April 19, 2024 | The Latest Buzz for the Appraisal Industry

National Appraiser Regulatory System

We often hear from our readers that the appraisal system needs to be changed. It is not very often that someone takes the time to layout the changes they would like to see. Below is an article from Don Clark on what changes he thinks we need to see in the profession and his response to the recent bulletins from  The Appraisal Foundation and The Appraisal Institute

The Memorandum and letter put into context, a situation that has been brewing for sometime now between the Appraisal Institute and The Appraisal Foundation. As a Professional Appraiser who is not a member of the Appraisal Institute (AI), nor any other National Appraisal Organization, but is an AQB Certified USPAP Instructor of The Appraisal Foundation (TAF), and a member of two state Appraisers Coalitions, I do have some thoughts on the issues that are addressed by both. However, I do believe that many of the issues can be resolved by both stepping up to the plate and doing what is best for all appraisers, not individual organizations.

As I see it, there are some real and urgent issues facing the appraisal profession, and my thoughts are how they might be resolved:

  1. Increasing and continuing loss of real estate appraisers nationwide. This has been a concern in many states for some time now. Both the AI and TAF have ideas about who and how an appraiser can enter the profession, that to me at least, are idealistic and unrealistic. The primary consideration is the educational requirements for entry. In my opinion they are too stringent, and have resulted in less and less individuals entering the profession. A solution would be to roll back the educational requirements to those prior to 2008. I doubt that there are very many people with a 4 year degree or higher that are enthusiastic about entering the profession. The hours, compensation, and recognition are just not there.
  1. The licensure level is unrealistic. There should be one type of licensure: Certified Real Estate Appraiser. The 3 levels we have now are unrealistic, too arbitrary, and keep many good and well-qualified appraisers from doing what they have the competence to do based on demand of the market place. It is the market place and individual clients and appraisers who should be deciding what type of properties an appraiser can appraise, based on their knowledge of the real estate, it’s complexity, and geographical location. Just as many states have gone to only one form of licensure for real estate agents based on similar criteria, so should such criteria be applied to a real estate appraiser.
  1. Licensure, educational requirements, and the qualifications of an individual should be determined by the states, not a Professional Appraisal Organization or any other National entity.
  1. Continuing education needs to be totally revamped. Appraisers year after year are forced to take the same subject courses over and over again for little justifiable reason. It is my opinion that, with the exception of changes to The Uniform Standards of Professional Appraisal Practice (USPAP), there is no need to take any course more than once every 5 years.
  1. The Uniform Standards of Professional Appraisal Practice (USPAP) should be for a period of 5 years, with appropriate changes made at the time and date they are necessary. This is done very well for example, by the Federal Government. Any agency and the Military have manuals that are subject to continuing change, with the item/subject that is changed being replaced with a newer and more up to date version. In my 20 years in the U. S. Navy I made hundreds of changes to such manuals on a continuing basis. To rewrite a manual every two years seems literally to be a waste of time, effort, and money. The manuals could be the subject of an audit by state regulatory boards.

That is my “Five Point Plan” that I believe would resolve many of the issues of contention between the AI and TAF.

In my opinion it is far better for the parties to work this out than to have the Federal Government do so. It would also put the real estate appraisal profession under the regulatory process of the states more solidly than it is now, and that is where it belongs.

Have any comments or would you like to submit content of your own? Email comments@appraisalbuzz.com

Brent Bowen

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