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Latest AQB Proposal on College Degree, Experience Requirements
by Isaac Peck, Editor
On September 17, the Appraisers Qualifications Board (AQB) issued its second exposure draft doubling down on its proposed rollback of the Bachelor’s Degree requirement for Certified Residential appraisers. The exposure draft also addresses the experience requirements that are necessary to become an appraiser and achieve the Licensed, Certified, and Certified General credentials.
Amidst talk of a present or impending appraiser shortage, the AQB is taking a clear position that certain aspects of the current Real Property Appraiser Qualification Criteria “may not be necessary to maintain and promote public trust in the appraisal profession.” These proposed changes stand to have far reaching effects on the profession and should be of interest to all appraisers.
Bachelor’s Degree Requirement
Despite earlier indications from the AQB that the Bachelor’s degree requirement is here to stay, the AQB is now proposing the complete elimination of all college coursework for the Licensed Residential credential and the complete elimination of the Bachelor’s degree requirement for the Certified Residential credential. Instead, candidates would now only need an Associate’s degree to become Certified.
In keeping with the first exposure draft in May 2016, the AQB also will offer an alternate path to Certification to those candidates who do not wish to complete an Associate’s degree. With the alternate path, candidates would only need to pass a series of College-Level Examination Program (CLEP) exams covering the following areas: (1) College Algebra, (2) College Composition, (3) College Composition Modular, (4) College Mathematics, (5) Principles of Macroeconomics, (6) Principles of Microeconomics, and (7) Introductory Business Law.
A third alternate in lieu of the Associate’s degree would be for a candidate to complete 21 semester hours of accredited college level coursework in the following subjects: six hours of english composition, six hours of economics or finance, six hours of mathematics (algebra or higher), and three hours of business or real estate law.
By proposing the elimination of the Bachelor’s degree requirement, the AQB seems to be listening to the consensus of many rank and file appraisers. Working RE’s most recent Future of Appraisers survey, in which over 3,800 appraisers participated, indicates that 60% of appraisers who responded are opposed to the bachelor’s degree requirement, with 82% in favor of a path to Certification without a bachelor’s degree.
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Education Instead of Experience?
In its first exposure draft in May 2016, the AQB initially proposed the creation of Practical Applications of Real Estate Appraisal coursework, or Practicum coursework, that could be used to satisfy up to 100% of a would-be appraisers experience requirements when pursuing the Certified Residential credential. The AQB writes that “Respondents were mixed in their support or non-support for this alternative type of experience” and that “many viewed this as non-real world experience and objected to its accounting for the entire experience level.”
The AQB appears to be heeding the warnings of appraisers who are critical of this approach, and based on the feedback of its first draft, is now proposing that the Practicum coursework would be eligible for no more than 50% of a candidate’s total experience requirement.
Even with this proposed change, the AQB acknowledges that further work is needed to develop the standards and course outlines and writes that this important topic will be explored further in a separate, subsequent exposure draft.
Experience Requirements
While the AQB appears to be walking back its earlier proposal of allowing Practicum coursework to account for 100% of a candidate’s appraisal experience, its second exposure draft nonetheless proposes significant changes to the appraiser experience requirements.
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The AQB is proposing revising the experience hours required as follows:
-Licensed Residential: 1,000 hours of experience (no minimum time frame)
-Certified Residential: 1,500 hours of experience (no minimum time frame)
-Certified General: 2,000 hours of experience, with at least 1,000 hours in non-residential appraisal (no minimum time frame)
Such a move would reduce the required hours for each credential by 1,000 hours and remove the minimum timeframe limitation that previously required would-be appraisers to wait 12, 24, or 30 months to achieve a particular credential.
In its rationale for why it finds such changes necessary and timely, the AQB writes that while the experience requirements have not increased since 1998, there have been substantial enhancements in education and examination components of the Criteria that make it appropriate to reduce the experience requirements.
Among such enhancements that the AQB cites as evidence of increased education and examination requirements are: the number of qualifying education hours has increased dramatically; qualifying education now includes case studies and report writing courses; college level education or testing is now required for the Certified credential categories; applicants are now required to pass uniform exams that are increasingly intensive, and there now exist qualification requirements for supervisory appraisers. In other words, because the education, testing, and training systems for qualifying appraisers have improved, the AQB is proposing that the experience requirements can be reduced without sacrificing the quality of the appraiser training process or endangering the public trust.
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The AQB acknowledges that some will resist such a proposal because more substantial experience requirements have been “used by professional appraiser organizations for decades” and that “reducing the number of hours of experience needed for a credential or doing away with the experience requirement altogether,” will be unacceptable to many.
As its reasoning, the AQB writes that its charge is “to maintain and promote public trust in the appraisal profession by establishing the minimum qualifications necessary to obtain a credential” and argues that it is appropriate to consider offering “a more balanced approach to the qualifications needed for a credential by reducing the number of hours of experience required.”
As part of this second draft, the AQB also has decided that it will not allow the use of experience in other professions as a method of qualifying towards a real property appraiser credential. The AQB writes that while some professions may offer valuable experience, “quantifying and reconciling such experience, as it relates to appraising, would be tremendously difficult.”
Timeframe for Changes
Appraisers hoping for quick relief on the bachelor’s degree or experience requirements will need to be patient. The AQB writes that depending on the feedback received and timing of any subsequent exposure drafts, any changes, if adopted, will go into effect no sooner than January 1, 2018.
Send Your Feedback!
Appraisers are encouraged to submit their (concise and considered) comments to the AQB before the November 18, 2016 deadline: Email: aqbcomments@appraisalfoundation.org or mail to: Appraiser Qualifications Board, The Appraisal Foundation, 1155 15th Street, NW, Suite 1111, Washington, DC 20005.
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About the Author
Isaac Peck is the Editor of Working RE magazine and the Director of Marketing at OREP.org, a leading provider of E&O insurance for appraisers, inspectors and other real estate professionals in 49 states. He received his Master’s Degree in Accounting at San Diego State University. He can be contacted at Isaac@orep.org or (888) 347-5273.
Send your story submission/idea to the Editor: isaac@orep.org
by Mike
Obviously the AMC are in control. Soon the requirements will be a GED and a willingness to do appraisal work for minimum wages and carry insurance to protect the AMC. What a joke. There is no shortage of appraisers only a shortage of those willing to be underpaid.
-by Kyler
There is no shortage of qualified trainees. I receive a call weekly from bright and qualified potential trainees that have their bachelors and are willing to sacrifice for years to gain the experience and knowledge to become a well qualified appraiser. What we don’t have are certified appraisers willing to take the necessary time from their already busy schedule to train. Incentivize your trainers. Set-up a trainee program that would guide both the trainer and trainee through this process in a streamlined fashion. Likely there would have to be a monetary incentive for the trainer. At least in this market.
-by Terry
Simple if you want more appraisers regardless of requirements get rid of the AMC’S
-by Certified Appraiser
So, “amidst talk of a present of impending appraiser shortage” the AQB is reversing its position on Appraiser Qualification Criteria and now states that it “may not be necessary to maintain and promote public trust in the appraisal profession.”
-Both of their positions, proposing the new qualifications, and their potential reversal on that very position, simply illustrates their obvious lack of due diligence in developing and supporting either position. How does reducing the experience requirements for each level of appraiser licensure or certification make for more experienced appraisers? How does eliminating the bachelors degree criteria aid promoting the public trust of the appraisal profession? This would be a watering down of the criteria of the appraisal profession to make it more of a commodity-driven industry where fee and turn-time trump actual educational background, knowledge, experience, and geographic and property-type competence. This geographic competence and experience in appraising various types of residential properties only comes with years of working in the field. So, if the AQB wants to reduce the educational requirements, it should increase the experience requirements, not reduce both. I have a bachelor’s degree in Business with focus on Real Estate and Urban Land Development and have over 450-hours of real estate-related courses. This educational background was fundamental in establishing myself in the appraisal profession. However, in my opinion, there is no substitute for actual field experience and training. Most any appraiser can appraise the basic property in a standard subdivision, but it an educational background and years of actual field experience to handle any assignment that a client may order. More educational background and more field experience is the key to strengthening the appraisal profession and truly maintaining the public trust in our profession. Let’s see if the AQB maintains its position of “a more balanced approach to qualifications” when we have the next economic downturn in the next few years. As to the appraiser shortage mantra being pushed by the AMCs, lenders, realty agents, NAR, and other self-interested parties, I find it to be a baseless and unsupported position. The appraisal profession has been devastated by government intervention which changed the entire structure of the industry. Fees are down, trainee appraisers are not supported by the current structure, and more and more appraisers refuse to work for the below-market and non-customary and unreasonable fees being offered by the current structure that was imposed on the profession. The fact is that there is a shortage of appraisers who will tolerate low fees, expedited turn times, and ridiculous ten-page vendor assignment conditions that the powers that be have imposed on them since 2009. So, the AQB’s answer is to lower the bar to entry into the appraisal profession so lenders and AMC’s will have a steady stream of low-cost appraisers to which to send their appraisal work. This is not about appraisers or the appraisal profession, this is about all of the users of appraisals clamoring about a perceived appraiser shortage.
by John
The AQB is just slapping the faces of all the appraisers who in the past have had to get a degree and had to get all those experience credits. It’s now too hard for the these new potential appraisers to do this so just give them a pass just like our local high schools do. Push them on through. How about the AQB eliminate the 56 hrs. of continuous education requirements they’ve imposed on all appraisers after they do become qualified and Certified? Can’t do that.
-by Brent Johnson, SRA
So, whenever there is a shortage of professional services, just roll back the educational and experience requirements; that’ll fix the issue. With respect to the appraisal profession, this will simply send the appraisal professional back to competing with non-professionals. With the AQB proposal, should one invest in new computers and software, or a new pickup and lawnmowers? The ABA and mortgage lobbyists win again – why protect the public with college degrees and experience during the transition with historic non-market interest rates if it impacts appraisal fees. If successful, this effort will send the profession back to the kitchen and spare bedroom.
-Nice work AQB, way to protect the public and promote the profession.
by Phyllis@closet.com
How can you reduce the fieldwork requirement and keep the public trust? That would be like eliminating the “hospital residency requirement” for medical doctors! Experience is what makes an appraiser. The ability to say you saw it before handled it appropriately is what makes a good appraiser. Increasing the herd for the AMC’s is what this is all about!
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