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NAR Responds to AQB Exposure Draft

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Francois K. Gregoire

Senior Member
Jan 14, 2002
Professional Status
Certified Residential Appraiser
Good Morning All,

Here is a link to the NAR response to the AQB Exposure Draft on Revising the Real Property Appraiser Qualification Criteria.

Thanks to all participating in the drafting of the response. Our comments are based upon a survey of REALTOR Appraisers conducted in late 2000 and early 2001 and numerous comments received from members and non-members over the past eighteen months. Four members of the Appraisal Committee participated in the drafting of this letter. Because there will likely be disagreement expressed by some out there in Wayne's World, they can identify themselves if they wish, but I'll take the heat.


Comments Welcomed. The AQB has already indicated they intend to digest all the comments and information received and submit a Revised Exposure Draft later this year.

David C. Johnson

Senior Member
Jan 15, 2002
<span style='color:darkblue'>Frank,

I think the NAR Response is very good -- well written. It is not insulting to one's intelligence or sense of fair play. It has a new candor that was less obvious in a previous draft. It is based on increased reasoning, and again and most important, appears particularly direct and transparent for a document of this type. I detect your sharp mind, interest in integrity of argument and unusual diligence at work. If I have wrongly apportioned due credit, it maybe a more general testament to the caliber of NAR's leadership.

Subterfugeless: The Final Story for Rogain:

In my opinion, Madison Avenue Marketing-types shot themselves in the foot and performed a serious disservice to the owners of Rogaine in their initial advice for advertising and selling this product. In their zeal to succeed -- including the standard deception and exaggerated claims as accepted marketing protocol -- they outsmarted themselves. They completely overlooked their very best market as well as their best sales strategy: the Truth. Their real market was NEVER those who had already lost their hair! The formula is marginally and sporadically effective for regrowth -- particularly after years of baldness. They wasted several years of exceptional profits. Their actual market -- which was many, many times larger and much more profitable -- was to those who were concerned about loosing their hair in the first place! -- where the product is exceptionally good indeed. As was documented early on, it certainly does prevent many common types of hair loss. To their misfortune, they had overlooked the truth!

(Yep, I use it just for that purpose -- even before Madison Ave. caught on I'm gratified to say. Ironically it increases apparent hair loss in the first few weeks of use, but actually is upgrading the chemical structure and function of the hair follicles themselves where these particular hairs are goners anyway, but will in fact grow back. Rogaine was originally researched and developed for cancer patients who lose hair as a side effect of chemotherapy.)

I have long figured that one of the Realtors' main interests in the proposed increased education and/or college education issue is to retain the option for their agents and brokers to switch to appraising as a career option should they choose to do so in the future. Not all of them have college eductions and would not be "grandfathered." The fact is this group is exceptionally experienced in the field of real estate -- certainly including valuations. This is a very legitimate issue and concern, and was for the first time (unless I missed it previously) so clearly spelled out. In support of this position (as well as others perhaps), additional very rational arguments have now been forwarded including the concern for increased AVM use (& possibly BPOs) as an unintended market consequence; also, further apparent inconsistencies -- supportive of the cause -- in the overall proposed AQB game plan were then outlined. Good move and wise move in my opinion.

Charles Darwin & Diligence of Research

Sure, he did years of research towards his theory and preparing his book, "Origin of the Species." I'm not talking about that. I am talking about the extensive research he conducted of his peers in science, and their attitudes and objections, from across the globe prior to publishing. He carried on correspondence via letters for months to the key players in the world science community. He knew his life would be forever greatly impacted from the book. He was right. However, he had not only primed his audience in advance but also made for the opportunity to prepare more effective rebuttal right from the start (which was incorporated into the first release). We have seen similar work of yours on this appraiser's forum and others, which I believe has been effective and is to be admired and commended.

All together are likely advantages of NAR's position worth the tradeoff of a potentially more prestigious profession via a higher educational bar, and perhaps an accompanying reduction of gross new entries into the field? I don't know, but there's now several more concepts worthy of serious consideration, and part of the groundwork for a compromise may have been established.

Selected text from the Response:

"This change, alone, has the potential to create the very fear
that the crafters of TITLE XI of FIRREA envisioned -- a shortage
of appraisers. This proposal may have the unintended conse-
quence of creating an imbalance between supply and demand
resulting in unreasonable fees and may force clients and user
groups to find valuation alternatives. Many of these valuation
alternatives do nothing to protect consumers. The proposal,
despite the good intent, may work against goals to promote and
maintain a high level of public trust in the appraisal profession."

"The AQB proposal discounts the value of experience as an
alternative or substitute for formal education. For a young person
entering the profession, a college degree might indeed be a good
way of evaluating knowledge. However, in the case of a seasoned
real estate professional seeking a new career in real property
appraisal, a degree in an unrelated field has little value. The value
and importance of real estate related experience should not be
discounted or overlooked. We suggest the AQB consider experience
alternatives to the standards proposed."


David C. Johnson, Raleigh, NC
NC State-Certified General R.E. Appraiser
[email protected]</span>

Francois K. Gregoire

Senior Member
Jan 14, 2002
Professional Status
Certified Residential Appraiser

Thanks for taking the time to read the response letter. Given the significant effect the actions of the Appraiser Qualification Board have on our profession, it's a bit disappointing to see the level of appraiser interest in their actions.

Although my name is at the bottom of the letter, several folks contributed to it's crafting and should be acknowledged. Several points of view are represented, some of which were in support of increased educational requirements and college degrees. As noted above, the letter incorporates REALTOR - Appraiser comments from surveys and solicitations since late 2000. On of our primart concerns is the failure to present rationale for the increase in education and the presentation of apparently arbitrary requirements. None of this would be tolerated in an appraisal report. Why should it be accepted in a proposal from the AQB?

Significant power is concentrated in the hands and minds of five people. Five people you, State Regulatory Boards, I and all other appraisers have no say in appointing. The AQB has a record of paying little attention to negative responses to their proposals, choosing instead to concentrate on positive comments. There is little evidence the AQB examined information from any state regulators concerning their disciplinary experience. Our experience in Florida tends to indicate a majority of complaints allege ethical violations, not lack of competency. My conversations with other regulators over the past weekend shows other states have the same experience. Amazingly, some of these other states support the AQB proposal. This despite the fact states have the right to set a higher education threshold; the AQB criteria is minimum. How many states have a higher education requirement? I found one.
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