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Licensing - Maybe New Jersey In Particular

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TooMuchCoffeeGirl

Freshman Member
Joined
Jul 11, 2013
Professional Status
Certified General Appraiser
State
Pennsylvania
Can a person provide significant appraisal assistance (inspection, market research and analysis, area and neighborhood analysis, comparable sales research, inspection and analysis, value conclusion, and report writing) if they are not a trainee or certified? Pre-trainee, I know as long as you were acknowledged in the cert, there was a certain level of ok (foggy on whether a contributor was allowed to contribute to value conclusion). This is the first time since trainees came into existence that I've come across a report where someone was recognized that has no license at all, so I'm scratching my head and Jersey board isn't getting back to me.

Thanks for the help folks!
 

hastalavista

Elite Member
Joined
May 16, 2005
Professional Status
Certified General Appraiser
State
California
Can a person provide significant appraisal assistance (inspection, market research and analysis, area and neighborhood analysis, comparable sales research, inspection and analysis, value conclusion, and report writing) if they are not a trainee or certified?

Here's the response from the USPAP (this is from the 2018-19 version, but it is the same in the current version):

upload_2017-10-5_14-21-27.png

It would appear that only appraisers can provide "significant appraisal assistance" and only those appraisers need be cited in the report to comply.

The problem is that licensing is a "state" thing and not a USPAP thing. You don't have to be a licensed appraiser to follow the USPAP.
The best advice is to call your state regulator, describe your situation, and ask them if (a) the person meets the threshold for the significant appraisal assistance disclosure and (b) if they do, can they use those hours as experience hours for their licensing requirement.

Good luck!
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George Hatch

Elite Member
Gold Supporting Member
Joined
Jan 15, 2002
Professional Status
Certified General Appraiser
State
California
The qualifications at the state licensing level are spelled out in the state regs. Even if a state's interpretation is "wrong" they're still in control of it so from an applicant's perspective they're "right" no matter what.

In general, we define the applicability of appraisal standards based on the actions of the individual, not their title and not whatever other nomenclature might be used to describe those actions or that individual.

If an appraisal assignment requires completing a series of tasks, only some of those tasks require expertise as an appraiser to complete them. Within reason, anyone can measure a building or perform research or do data entry or take a picture. But it is an appraiser who does the unbiased analyses, opinions and conclusions, those being the primary tasks referenced in our appraisal standards. So when we refer to requirements to disclose professional appraisal assistance we are not talking about all of the other tasks in isolation from those analyses opinions and conclusions.

For example, my wife works with me and helps out in my inspections - she takes all the photos. She also does data entry and a certain amount of research such as pulling property records for my subject or comparables that I'm using in my appraisals. She doesn't do any analyses, opinions or conclusions, though; so from an appraisal standards perspective her role doesn't warrant disclosure in an appraisal report.
 

Meandering

Elite Member
Joined
Feb 26, 2006
Professional Status
Real Estate Agent or Broker
State
Pennsylvania
State Boards dont enforce FAQs, which aren't even a part of USPAP.

State Boards do enforce the Standards and Comments, which have no delineation of assistence recieved by other people or other appraisers, and infact, STANDARD 2-3 specifically includes others who are not appraisers.



USPAP Standard 2-a

(vii) summarize the scope of work used to develop the appraisal;

Comment: Because intended users’ reliance on an appraisal may be affected by the
scope of work, the report must enable them to be properly informed and not misled.
Sufficient information includes disclosure of research and analyses performed and
might also include disclosure of research and analyses not performed.

When any portion of the work involves significant real property appraisal assistance,
the appraiser must summarize the extent of that assistance. The name(s) of those
providing the significant real property appraisal assistance must be stated
in the
certification, in accordance with Standards Rule 2-3.23


USPAP Standard 2-3


When a signing appraiser(s) has relied on work done by appraisers and others who do not sign
the certification, the signing appraiser is responsible for the decision to rely on their work.
The signing appraiser(s) is required to have a reasonable basis for believing that those
individuals performing the work are competent. The signing appraiser(s) also must have no
reason to doubt that the work of those individuals is credible.

The names of individuals providing significant real property appraisal assistance who do not
sign a certification must be stated in the certification. It is not required that the description of
their assistance be contained in the certification, but disclosure of their assistance is required
in accordance with Standards Rule 2-2(a)(vii) or 2-2(b)(vii) as applicable.

.
 

jay trotta

Elite Member
Joined
Feb 8, 2004
Professional Status
Certified Residential Appraiser
State
Connecticut
State Boards dont enforce FAQs, which aren't even a part of USPAP.

State Boards do enforce the Standards and Comments, which have no delineation of assistence recieved by other people or other appraisers, and infact, STANDARD 2-3 specifically includes others who are not appraisers.



USPAP Standard 2-a

(vii) summarize the scope of work used to develop the appraisal;

Comment: Because intended users’ reliance on an appraisal may be affected by the
scope of work, the report must enable them to be properly informed and not misled.
Sufficient information includes disclosure of research and analyses performed and
might also include disclosure of research and analyses not performed.

When any portion of the work involves significant real property appraisal assistance,
the appraiser must summarize the extent of that assistance. The name(s) of those
providing the significant real property appraisal assistance must be stated
in the
certification, in accordance with Standards Rule 2-3.23


USPAP Standard 2-3


When a signing appraiser(s) has relied on work done by appraisers and others who do not sign
the certification, the signing appraiser is responsible for the decision to rely on their work.
The signing appraiser(s) is required to have a reasonable basis for believing that those
individuals performing the work are competent. The signing appraiser(s) also must have no
reason to doubt that the work of those individuals is credible.

The names of individuals providing significant real property appraisal assistance who do not
sign a certification must be stated in the certification. It is not required that the description of
their assistance be contained in the certification, but disclosure of their assistance is required
in accordance with Standards Rule 2-2(a)(vii) or 2-2(b)(vii) as applicable.

.

So when the Client/AMC State that a specific report type is USPAP compliant, they need to be able to Support that, along with a work file of the "assitance provided" and the names of those individuals from which the assitance was provided. In every review (stips) from an AMC, the signature of the inquirer Claimed to be a Certified appraiser and would be acting as a Supervisor ?
 

Meandering

Elite Member
Joined
Feb 26, 2006
Professional Status
Real Estate Agent or Broker
State
Pennsylvania
So when the Client/AMC State that a specific report type is USPAP compliant, they need to be able to Support that, along with a work file of the "assitance provided" and the names of those individuals from which the assitance was provided. In every review (stips) from an AMC, the signature of the inquirer Claimed to be a Certified appraiser and would be acting as a Supervisor ?

I'm confused as to what you are asking.
Why would an inquirer sign the report as either an appraiser or as a supervisor????

Please clarify your question.

.
 
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