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HUD, AQB and Licensed Appraisers

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Mike Phillips

Thread Starter
Senior Member
Dec 16, 2004
Professional Status
Certified Residential Appraiser
Per the AQB, please note the following: (my bold) (begin quote)

Under the provisions of Title XI of the Financial Institutions Reform, Recovery and Enforcement Act of 1989 (FIRREA), the AQB establishes the minimum education, experience and examination requirements for real property appraisers to obtain a state certification.

States are required to implement appraiser certification requirements that are no less stringent than those issued by the AQB in the Real Property Appraiser Qualification Criteria.

The AQB is aware that it has no statutory authority to develop criteria for the Licensed and Trainee classifications and the states are not required to adopt the criteria. The authority to develop requirements for the Licensed and Trainee classifications is vested in the individual states, territories and possessions.
(end quote)

IMO the above leads to the most valid argument for why HUD should no longer allow Licensed appraisers to be added to the FHA roster and why they should begin a phase-out of the Licensed appraisers currently on the roster.

The importance of the US residential housing market and the integrity of that market to the nation has been demonstrated. Needless to say, this nation is dealing with issues related to the residential housing market on a daily basis. The residential housing market is a national priority; it is not a state's rights issue anymore than the issue of discrimination is (or should be) a state's rights issue.

The failure of the individual states to regulate appraisers has also been demonstrated; no matter whether one feels it is the fault of the federal government (another unfunded mandate) or the individual states (who had other priorities) the fact remains, appraisers were not regulated by the states, and they are not being regulated today to the satisfaction of many individuals.

A federally funded department of the stature of HUD has no business allowing their appraiser qualification criteria to effectively vary based on the whims of 50 states. But that is exactly what they have done by setting the Licensed level as their minimum to be on their roster. The current individual state requirements to earn License level vary widely from "not much above what is required to become a Trainee" to "almost as much as is required to become Certified."

Once again, (from above), "The AQB is aware that it has no statutory authority to develop criteria for the Licensed and Trainee classifications and the states are not required to adopt the criteria." On the other hand "States are required to implement appraiser certification requirements."

BIG DIFFERENCE!!!. "Not required" should cause a bell to ring in the mind of every quality-oriented appraiser in the nation. In view of the demonstrated track record of the individual states regarding enforcement I have no confidence in the capacity or the willingness of their respective state appraisal board members or their state legislators to do anything but play to the will of the voters who put them in office.

Certification = Uniform standard for all 50 states.

Licensed = Whatever state boards and state legislators have the political will to require from their licensees.
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