; my license expires mid Feb; I do not expect to renew. If a client requests a condition or revision after expiration, can I still make a change? Am I obligated to respond? My belief is that I can not make an appraisal response if I'm not licensed, even if the OA was before expiration.
The answer is, it depends.
First, California is a non-mandatory state. That means anyone can do an appraisal.
For some assignments, a license or certification is required: those assignments are generally (a) mortgage finance related where an appraisal (as opposed to an evaluation) is required, or (b) scenarios where the client requires the appraisal to be completed by a licensed and/or certified appraiser (many private but legally binding agreements call for an appraisal in cases where real property rights need a valuation).
Non-licensed persons can also voluntarily follow the USPAP and sign the certification. So, a non-licensed valuer can do an appraisal and sign a USPAP certification for certain scenarios. I've seen many such appraisals done for bankruptcy purposes.
I agree with you that if this is for a mortgage finance appraisal, and a request comes in after your license expires, you cannot alter the appraisal and re-submit because the assignment requires it to be completed by a licensed/certified appraiser. Since an alteration would require a new report date, my opinion is that submitting a signed-report after the expiration date of one's license would be counter to the assignment's engagement requirements.
Other states have different rules, so the ability to perform an appraisal if one is non-licensed/certified may vary from state to state.
Depending on what the request was, I might consider providing a written response. But that response would not be part of the appraisal and I wouldn't change the appraisal document.
If you do call BREA (which is good advice from Glenn) let us know what they say.
Good luck!
