Introduction: The Appraisal Foundation has recently issued its Second Exposure Draft outlining proposed changes to the Real Property Appraiser Qualification Criteria (Criteria). These changes primarily focus on qualifying and continuing education requirements, with a particular emphasis on valuation bias and fair housing laws and regulations. This blog post serves as a summary of the Second Exposure Draft, providing an overview of the proposed modifications.
Proposed Changes to Qualifying Education Hours: One significant proposed change involves an increase in the required qualifying education (QE) hours for certain credential levels. The Appraiser Qualifications Board (AQB) suggests that the QE requirements for the trainee classification and licensed residential (LR) classification should be raised by eight hours each. These increases are necessary because the trainee and LR classifications do not currently have any elective hours in their QE requirements. Consequently, adding new requirements without increasing the total number of QE hours would not be feasible. It is important to note that the certified residential (CR) and certified general (CG) classifications will not experience any change in their total QE hours.
If these changes are adopted, aspiring trainee appraisers would need to complete a total of 83 QE hours (compared to the current 75 hours), while LR appraisers would be required to complete 158 QE hours (instead of 150 hours). These hour counts are actual hours, not semester hours. Overall, the increase in hours is considered minimal in light of the valuable education on valuation bias and fair housing laws and regulations that appraisers would gain.
Using Fair Housing Education from the National Association of Realtors®: Appraisers who are also Realtors® may wonder whether the fair housing education they receive through the National Association of Realtors® can fulfill the AQB's proposed education requirements. It is important to note that Realtor®-centered fair housing courses typically cover different content than what is being proposed for appraiser education on this topic. However, if a Realtor®-centered course is approved in the state and meets the required content outlined by the AQB, it would fulfill the proposed education requirements.
Consideration of Integrating Valuation Bias and Fair Housing Content into Existing Courses: The AQB has explored the option of integrating valuation bias and fair housing content into all existing QE courses. However, this approach was deemed impractical due to implementation challenges. These topics are better addressed in a course solely focused on them. Incorporating the content into existing courses would burden course providers, make it difficult for appraisers to receive comprehensive education on all necessary aspects, and create challenges for regulators in tracking appraisers' training on the required content.
Enforcement of Bias and Fair Housing Issues: The AQB clarifies that enforcement of bias and fair housing laws and regulations falls outside its jurisdiction. While enforcement is crucial, the AQB and The Appraisal Foundation do not have the authority to make, judge, or enforce laws.
Proposed Changes to the 7-Hour National USPAP Update Course: The AQB proposes changing the name of the 7-Hour National USPAP Update Course to the "7-Hour National USPAP Continuing Education Course." This change aims to better reflect the purpose and content of the course. Additionally, the AQB suggests removing the "7-Hour" from the title of the 7-Hour Instructor Recertification Course, aligning it with the course's purpose and content.
Minor Edits: Some minor administrative edits are proposed in the Second Exposure Draft for clarification purposes. These edits do not result in substantial changes to the Criteria.
Timing of Proposed Changes: The proposed changes are expected to be included in new Criteria to be adopted at a public meeting on June 22, 2023. The changes are scheduled to take effect on January 1, 2026. This extended effective date allows ample time for states to successfully implement the changes, considering variations in their regulatory processes.
Conclusion: The Appraisal Foundation's Second Exposure Draft presents proposed changes to the Real Property Appraiser Qualification Criteria, focusing on qualifying and continuing education requirements. The modifications aim to enhance appraisers' understanding of valuation bias and fair housing laws and regulations. Stakeholders have provided feedback, leading to adjustments in the proposed requirements. By adopting these changes, the industry strives to ensure appraisers receive comprehensive education and remain well-equipped to address complex issues in their profession.
Overview of Proposed Changes: (Per Second Exposure Draft)
The AQB is proposing to revise the current continuing education requirements. The proposal is to require a portion of the existing required continuing education hours meet specific content requirements.
Currently, for an appraiser seeking to keep their license or certification current, two of the continuing education requirements in the Criteria which apply are:
(1) Appraisers must successfully complete the 7-Hour National USPAP Update Course, or its AQB-approved equivalent, every two calendar years. Equivalency shall be determined through the AQB Course Approval Program or by an alternate method established by the AQB.
(2) The equivalent of fourteen (14) class hours of instruction in courses or seminars for each year during the period preceding the renewal is required. For example, a two-year continuing education cycle would require twenty-eight hours. The class hour requirement can be fulfilled at any time during the cycle.
In other words, every two calendar-year period in an appraiser’s education cycle currently requires twenty-eight hours of continuing education, of which seven hours must be obtained from successfully completing the 7-Hour National USPAP Update Course. This existing requirement allows the appraiser to choose how they obtain the other twenty-one hours of mandatory continuing education. The AQB is proposing to require a portion of those remaining twenty-one hours be allocated to a valuation bias and fair housing laws and regulations course.