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Licensure Can-do Question?

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ZZGAMAZZ

Thread Starter
Senior Member
Joined
Jul 23, 2007
Professional Status
Certified Residential Appraiser
State
California
Appraiser carelessly let her license expire (temporarily) and is waiting for the state to approve her renewal application.

Lender requests additional comps for a job done recently, when the license was in effect.

Can the appraiser respond (on a date when she is not licensed) by saying that she is not inclined to provide additional comparables because the original report satisfies lending guidelines, in her opinion?
 

Randolph Kinney

Elite Member
Joined
Apr 7, 2005
Professional Status
Retired Appraiser
State
North Carolina
Appraiser carelessly let her license expire (temporarily) and is waiting for the state to approve her renewal application.

Lender requests additional comps for a job done recently, when the license was in effect.

Can the appraiser respond (on a date when she is not licensed) by saying that she is not inclined to provide additional comparables because the original report satisfies lending guidelines, in her opinion?
Hmmm ... how to "skirt" the issue.

Well, as a non licensed appraiser, anything I would supply after my license expiration would not be placed in my original appraisal report. Any communications I would have would be in the role of a private party, not as a licensed appraiser.
 

Thomas Fiehler

Senior Member
Joined
Jun 2, 2003
Professional Status
Certified General Appraiser
State
Ohio
Need to check with your State. If licensing is mandatory then likely not. but, TJMHO.
 

Don Clark

Elite Member
Joined
Jan 17, 2002
Professional Status
Certified Residential Appraiser
State
Virginia
I would let them know that your license is not in effect at the present time due to the cited circumstance, and you cannot respond until license has been reinstated. By then they will likely have gone away.
 

Lawrence R.

Senior Member
Joined
Mar 27, 2007
Professional Status
Certified General Appraiser
State
South Carolina
In my state, I didn't see much stated about this particular circumstance. I would think that once you explained that you didn't currently have an active license, the conversation would be over.

However, anyone can send anybody data. As an unlicensed regular joe, you are only prohibited from providing an appraisal.

I think as long as there was no opinion of value given, you could do it. But I wouldn't adjust the comparables--that could be construed as appraising. If they just want extra sales in the area, I would think you could provide it, OUTSIDE of the contents of the original appriasal.

But personally I wouldn't do it. If it came back on you it would be really really sticky.
 

Mike Kennedy

Elite Member
Joined
Sep 28, 2003
Professional Status
Certified Residential Appraiser
State
New York
Appraiser carelessly let her license expire (temporarily) and is waiting for the state to approve her renewal application.

Lender requests additional comps for a job done recently, when the license was in effect.

Can the appraiser respond (on a date when she is not licensed) by saying that she is not inclined to provide additional comparables because the original report satisfies lending guidelines, in her opinion?

As a NON-LICENSED person - she is NOT qualifed to render ANY opinion nor provide ANY data for an appraisal performed for an FRT. If located in a state which legally PROHIBITS any individual from PURPORTING to be or ACTING as an Appraiser - her license renewal application CAN BE DENIED.

Additionally, an FRT LENDER accepting ANY opinions or additional "comparables" from a NON-LICENSED individual is in violation of OCC AND FDIC regulations .....and quite probably State Banking Laws.
 

Lost Cause

Senior Member
Joined
Sep 17, 2004
Professional Status
Certified General Appraiser
State
New York
Going Overboard?

As a NON-LICENSED person - she is NOT qualifed to render ANY opinion nor provide ANY data for an appraisal performed for an FRT. If located in a state which legally PROHIBITS any individual from PURPORTING to be or ACTING as an Appraiser - her license renewal application CAN BE DENIED.

Additionally, an FRT LENDER accepting ANY opinions or additional "comparables" from a NON-LICENSED individual is in violation of OCC AND FDIC regulations .....and quite probably State Banking Laws.
Technically, no doubt. Materially? I seriously doubt that there would be any consequences under the cited circumstances.
 

Caligirl

Senior Member
Joined
Jan 27, 2006
Professional Status
Certified General Appraiser
State
California
Take a vacation-return when your renewal arrives.

JMO.
 

Mike Boyd

Elite Member
Joined
Jan 18, 2002
Professional Status
Retired Appraiser
State
California
Is providing a comparable sale without a value conclusion considered to be an appraisal? A little scary maybe but I don't think you would be censured too badly, if at all.
 

Couch Potato

Elite Member
Joined
Mar 15, 2004
Professional Status
Certified Residential Appraiser
State
North Carolina
Although it may never be noticed, try explaining it to your client. To do otherwise could lead to serious problems since USPAP requires compliance with the following:
The COMPETENCY RULE requires recognition of, and compliance with, laws and regulations that apply to the appraiser or to the assignment.
 
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