I'm not so sure. Yeah it would be great to jump up from CR to CG. If only to get a fair shake on all the residential work and clients scoot ahead of me in line and take. But if this became a reality we'd all have to do that in order to compete. Just like when the demins rose and the entire body of regular licensed people could no longer complete all this mortgage lending work, and I think also FHA. There was some big event back in the day and all the licensed appraisers raced into certification, even though certification had never been a requirement for them to stay in business before. And now regular licensed is pretty rare, most people left are CR's or CG's. Runs counter to logic because there should be more residential work than commercial, hence a lower volume of CG's. Same thing will happen with a PAREA to CG, everyone will race to it out of necessity even if they don't really want or need the licensing upgrade. None of it matters anyways, if appraisers don't rally and save the mortgage lending side all the other specialty niches and non ML work will fall in short order. None of your licenses are going to matter for much longer. May take another decade but the wheels are already in motion.
Let's talk about every single stake holder and and manager of this industries policies and regulations being required to have an appraisers license themselves instead. Then we can talk about requirements for anyone whom distributes appraisal orders, or has anything to do with distributing or providing administrative reviews to appraisal orders, or managing appraiser approval panels, or managing anything to do with appraisers, to be required to have an appraisers license themselves. And we'll talk about the need for transparency in AVM systems. You can read the patents and learn how they really work, and they are very very easy to manipulate and nobody would know whom manipulated them or exactly when or why. Those effects on markets are already visible with so many deals going through the value acceptance program even today.
Don't mistake a loop hole and deceptive work around to stretch out the exploitation of this industry, the special favor of TAF and AI to interested party lenders and fintech's, which is the PAREA program, don't mistake that for legitimate opportunity. Because it's not. It's a trap and everyone whom requests such a thing is taking the bait. If you want CG, take the classes, advertise that you have already passed the CG test, can do so again on a moments notice, and call around and find a CG to give you the hours. Work for free if you have to, just get it done. Either you are ready for that or you are not. No clever regulatory carve out should be necessary in the first place. If you want it, go get it. Earn the credentials properly or you'll just be going through the motions for a piece of paper. You thought liability in residential was daunting? You ain't seen nothing yet if you dive head first into commercial without the proper training. The last thing we need is every residential focused appraiser having a CG, we have enough of those already, more than enough, an excess of them.
