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AQB Considers Changes to College Degree, Experience Requirements (Again)
By Isaac Peck, Editor
On November 1, 2017, the Appraiser Qualifications Board (AQB) issued its 4th Exposure Draft on its proposed changes to the Real Property Appraiser Qualification Criteria.
The AQB writes that after examining this issue in-depth for over two years it believes that the public trust “can be served without requiring college-level education for the Licensed Residential credential, and by allowing alternatives to the bachelor’s degree requirement for the Certified Residential credential.” The AQB reports that it has received “an unprecedented level of feedback” on this issue and acknowledges that there is clearly a “great divergence of opinion.” However, the AQB indicates that, in lieu of a bachelor’s degree, there are alternatives that can “achieve a similar level of public trust in the residential appraisal marketplace.” Supporting the argument that the bachelor’s degree requirement will lead to a shortage of appraisers, the AQB writes that these degree alternatives are desirable because they will ensure “an adequate supply of qualified appraisers.”
The AQB makes a point of noting that it “does not establish Criteria with the intent to affect the supply of appraisers,” but adds that “a healthy balance of supply and demand certainly assists with protecting public trust in the appraisal profession.” As for what alternatives should be allowed in lieu of a bachelor’s degree, the AQB proposes (1) An associate’s degree in business, finance, accounting, economics, or similar programs, or (2) Successful completion of 30 college semester credit hours in specified topics, or (3) Successful completion of College-Level Examination Program (CLEP) exams equivalent to a minimum of 30 semester credit hours in specified subject matter areas; or (4) Any combination of #2 and #3 that includes all of the topics identified. The topics to be covered in the 30 college semester credit hours and/or CLEP tests include English Composition, Micro-Economics, Macro- Economics, Finance, Algebra, Geometry, Statistics, Business or Real Estate Law, and other closely related topics.
The AQB also addresses its earlier proposal of developing coursework that could be used to substitute an appraiser’s experience hours, which it refers to as the Practical Applications of Real Estate Appraisal curriculum (PAREA). PAREA coursework would “provide an alternative to gaining experience in the traditional sense of training (i.e., in an appraisal office with a supervisor mentoring the trainee).” The AQB writes that it has received widespread support for the PAREA concept, in part because of “the current lack of training opportunities in appraisal firms and the financial disincentives inherent in training programs for both the mentors and trainees.” The AQB indicates that some of the responses it received regarding this topic “conveyed a lack of understanding of the AQB’s goals in developing this alternative form of experience” and that “the goal of the practical applications program would be to emulate actual field experience, and the module structures would include actual field experience.”
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However, because of the varied responses it received, the AQB is withdrawing the PAREA concept from its 4th Exposure Draft and will look to provide “more information and illustration…in order for responders to credibly evaluate this concept.” The AQB plans to continue developing the PAREA concept and advises that appraisers should look for additional information on PAREA in the coming months.
Lastly, in keeping with its earlier proposed changes, the AQB is proposing revising downward the experience hours required for both the Licensed Residential and Certified Residential credentials. For the Licensed Residential, only 1,000 hours of experience would be required (six month’s minimum timeframe). For the Certified Residential credential, only 1,500 hours of experience would be required (12 months minimum timeframe). For the Certified General, the 3,000 hour experience requirement is left intact, but the minimum timeframe is cut down from 30 months to 18 months.
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 as well as the minimum timeframes. In response to critics who oppose reducing the experience requirements, the AQB draws a distinction between being competent and qualified, writing that the AQB Criteria “must ensure that an individual is qualified to appraise, even though that individual may not necessarily be competent yet. Competency is gained over time based on an appraiser’s practice. Regardless of the amount of experience required to obtain a credential, there will always be assignments appraisers are not competent to perform at the time they initially receive a credential.”
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Appraisers are encouraged to submit their comments to the AQB before the Friday, January 12, 2017 deadline: Email: aqbcomments@appraisalfoundation.org or mail to: Appraiser Qualifications Board, The Appraisal Foundation, 1155 15th Street, NW, Suite 1111, Washington, DC 20005. The AQB will also accept verbal comments at its public meeting in Washington, DC on Thursday, February 1, 2018.
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About the Author
Isaac Peck is the Editor of Working RE magazine and the Director of Marketing at OREP, a leading provider of E&O insurance for home inspectors, appraisers, and other real estate professionals in all 50 states and D.C. 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.
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by Dave
I hope these changes go into effect. I’ve been in the appraisal business since 2001. I have had years of experience with all type of appraisal products, however, in my area, I was never able to find an appraiser that would take on an apprentice. Over the past few years, I developed a good working relationship with an Appraiser who is more than willing to have me as an apprentice. I obtained my trainee license, however I do not have a Bachelors degree and have been unable to continue with obtaining an appraisal license. These changes would assist me in obtaining an appraisal license greatly.
-by Arty
How can you be an appraiser if you don’t know how a well, septic, furnace, sump-pump, French Drain, vent fans, etc. work? How can you call for FHA repairs if you don’t know how things operate, function or why they were installed? Substituting education for lots of field work is a fools game!
-by Dean Rylander
One important item to clarify is that the PAREA concept is being removed from this exposure draft and will be considered separately. The AQB has recognized the need for actual field experience and has stated it would be included in the module structure. The exact form this “field experience” will take in the modules is unknown at this point but its importance has been recognized. Providing our feedback to the AQB on this issue as it is developed will be critical and I believe the opportunity will be provided.
-Upon implementation of the Practical Application of Real Estate Appraisal (PAREA) concept – This live classroom education could provide substantial credit towards the experience hours, but not all, leaving 500 hours to be completed with a supervisor for geographical competency and in the field training. This would further reduce barriers into the appraisal profession while at the same time shortening the Supervisor / Trainee Apprenticeship period and further protect the public trust.
I support the advancement of the proposed Practical Application of Real Estate Appraisal (PAREA) concept. I believe finding a supervisor willing to supervise a trainee is the most significant barrier to entry into the appraisal profession. The proposed PAREA concept has the potential to address this barrier in a manner that would also protect the public trust and be highly beneficial to the appraisal profession. I am greatly disappointed in delaying development of PAREA. Therefore, strongly urge the AQB to consider the development of PAREA an immediate priority and provide a specific timeline. If not addressed immediately, some other “player in the field” will address this real-world problem for us, and you may not like the outcome!!!!!
by Stephanie
Experience is a must. Hands on training is the best way for someone to learn and understand in any line of work. Having a College degree doesnt make a person a better appraiser. Most colleges don’t even have appraisal or real estate classes. Real estate is considered a trade that’s why for years there have been separate schools directly for appraisers, & realtor. The shortage is because of these ridiculous AMC’S and the amount of work us appraisers are putting in for lack of pay, respect, and acknowledgement for our hard work. You got these AMC increasing the appraisal fee to pay themselves , when the appraiser is not the one who hired them the lender does.
-Also why should any new criteria put into effect have any baring on people who already hold a certification a license and an assistant license . We should be grandfathered in . Most of the appraisers today are 35 and older with families and some not making enough to get by yet the AQB deciding to change criteria expecting existing appraisers who have put in years time and money every 2 years for continuing education and state renewal to go back to college in order to upgrade there license. That’s a real slap in the face. The best part is now after 2 years they realize the changes were not a good idea that they need to go back and revise the qualifications. In the mean time they should have put back the old way so existing appraiser could upgrade their license.
No, they have us appraisers waiting for the revised changes as if this is a game. This is our life , time, and career your playing with. The last 2 years you have asked for fees back and it’s been negative and if you ask me if the AQB needs validation and feedback they have no idea what there doing and should have not made any changes .
by Joseph Robbins
Hi:
I have been appraising land and residences in four counties in Maine since 1979. I
cannot get an upgrade to certified residential because of the AQB.
This was a move several years ago by a majority of certified licensees (90+% who
lied as to their qualifications when licensing became law) to cut out the
competition. Now the number of appraisers is getting smaller and smaller. I have
trained 5 appraisers. I am not allowed to do this any more.
A large percent of my work was FHA. I can’t appraise for them any longer.
Most appraisal companies in Maine are family oriented now (the daughter, idiot son,
do nothing son in law). When is common sense going to rule again? Last month the
Maine Appraisal Board allowed appraisers to come speak at their meetings and I spoke about these matters. Their response is AQB makes the rules.
Well I’m here to tell you the system is flawed boys and girls.
Joseph Robbins
-AP752
by Mark Woodson
Not requiring a college degree means you(AQB) are wholly and totally making it obvious you work only for the AMC’s and other special interests. You do not serve appraisers.
The only people who think there is an appraiser shortage are companies who want to pay a substandard fee and cant find people willing to work for min wage.
There is NOT a shortage. Ask any appraiser, do NOT ask a company that hires appraisers for sub-standard fees.
Being asked to do a multi-family appraisal in a rural mountain community with only 4 multi-family sales in the last 5 years for $350 and turning it down or requesting a customary and reasonable fee does NOT mean there is a shortage!!!!!
Finding out an appraiser from 7 counties away(300 miles) without MLS access took the assignment and its been 3 months and the report keeps being returned for incompetency does not mean $350 is reasonable and customary!
Lastly-changing experience requirements is another move to pacify the worthless AMC companies who are screaming they cant find underpaid, incompetent appraisers. The only “widespread support” for PAREA has come from vendors vying to reach the bottom of the barrel in quality and fee, it has NOT come from any competent appraiser or a non-AMC vendor.
The level of appraisal experience is directly related to the quality of the report. This AQB statement is ludicrous, “…an individual is qualified to appraise, even though that individual may not necessarily be competent yet.”
You are telling me that an incompetent person can start doing appraisal? Doesnt USPAP directly address this in that there HAS to be competency?
At a certain point, it may be more money to be made flipping burgers with all these min wage increases than dealing with a supposed appraisal oversight agency that does NOT have appraisers and the public’s interest in mind.
-by Mike Ford, AGA, GAA, RAA, Realtor(r)
Mark, before HVCC there was no requirement for a degree at all. This was AQBs baby all along. It’s part elitism and part trying to find ways to keep justifying their existence.
TAF met the requirements of FIRREA many years ago. All they have done since then is to create work that make sit look like they are still necessary. They are not. Nor is TAF.
Even C&I work does not require a degree. It isn’t rocket science! Anyone capable of passing the test for it can do it-usually with a little more training specific to the particular property types encountered. We have many appraisal courses for those.
Think about it. The ONE thing that no one except them has ever called for is lowering of the experience requirements. The one area that college cannot prepare an appraiser for. Real world appraiser experience!
Whats really gallin gis that they continue to pretend they do this, along with changing USPAP every two years ‘for the protection of the public”.
-More like preservation of their own highly paid positions.
by Brad Mitchell
I think it is very important that a trainee appraiser has the opportunity to train with an experienced appraiser. It does make sense though that a trainee should receive more and better training before they begin training with a supervisor. I believe developing a program to make a trainee more knowledgeable before they begin training with a supervisor would give them a good understanding of the job before hand and make them more valuable as a trainee.
-by Mike Ford, AGA, GAA, RAA, Realtor(r)
I think there has already been enough tinkering with trainee requirements by TAF and state regulators. Why do you think we have a shortage of people willing to train in the first place? It used to be ‘difficult’ to find someone willing to train because their is a reciprocal commitment. We had to be very sure of each other.
I liked training. Right up until the state said that I have to also take courses in order to train. S C R E W them! I am willing to share my experience and skill. If you don’t think I am qualified to do that then don’t give me (or other sthe damn general certifications to begin with! make that test harder!
TAF and to some extent even ASC just don’t get it. There has already been far too much micro management of our independently owned and operated businesses. A lot of us got int this business because we don’t take kindly to corporate or government bureaucratic pony-loaf to begin with!
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