NEW Q & A

[Terrel L. Shields]

From TAF

Guidance on Valuation Bias and Fair Housing Laws and Regulations​

Course Requirements​

​

Can a CE version of the course count as QE?​

Question: What happens when individuals who currently have a credential take a course that meets​

the valuation bias and fair housing laws and regulations outline (VB-FH) for the 7-Hour course for​

Continuing Education (CE), and then they later upgrade? Do they then have to take the 8-hour VB-​

FH course (7 hour plus exam), just the exam, or are they considered grandfathered (with respect to​

the exam) because they held a credential at the time the new requirement was implemented?​

​

Answer: CE credit hours cannot be used to satisfy Qualifying Education (QE) requirements, with the​

following exception. If an individual seeking to upgrade their credential took a VB-FH 7-hour course​

during their most recent CE cycle, a state may recognize the CE course as meeting the QE​

requirement if the student takes and passes the required 1-hour exam component of the 8-hour VB-​

FH QE requirement. As a result, the student would not need to repeat the course content.​

​

It is important to note that both the CE and QE VB-FH courses must be currently approved by the​

state to qualify for this exception.​

​

Can the course include relevant state-specific content?​

Question: If a course that is intended to meet the Real Property Qualification Criteria’s outline for​

valuation bias and fair housing laws and regulations also includes relevant state-specific course​

materials on this topic, is the course eligible for QE or CE approval via the Appraisal Foundation’s​

Course Approval Program (CAP)?​

​

Answer: The outline for a course on valuation bias and fair housing laws and regulations in the 2026​

Criteria requires education developers to follow the complete outline when developing this course,​

which includes the federal fair housing and antidiscrimination laws and regulations topic. As stated,​

the requirement for the sections of the course that cover laws and regulations is that the course​

addresses federal fair housing and antidiscrimination laws and regulations.​

​

 

[Tawfik Ahdab]

Blah blah blah. All of this bloated bureaucratic edifice of nonsense is built on the undemonstrated premise of pervasive appraiser bias.

I am as against bias and discrimination as anyone who is an ethnic minority in this country could be, but I’ve received several demands by lenders to redact factual market information as a result of these new anti-discrimination laws. Not only does the omission of some socio-economic information about the market participants and the market area in general diminish the quality of the resulting appraisal report but, beyond that, it impedes the appraiser’s ability to freely research, identify, and report, the demand segment(s) that would be responsive to the real property under study.

Their pretext for demanding the omission of such information is that we are supposed to appraise the property and not the market participants. I would have no problem with that , except that a market is made up of buyers and sellers and understanding or at least describing patterns in their preferences (that is, market segmentation) is an integral component of proper appraisal practice.

What’s worse to me is that we appraisers are handed lists of prohibited words without the opportunity for rational discussion involving us who are the professionals censored. Not only that, but we don’t know who actually compiled these lists and what basis they had to select many words that are entirely neutral in meaning and application and that acquire a sinister aspect due only to the accusatory imaginations of the list- compilers.

 

[Terrel L. Shields]

I’ve received several demands by lenders to redact factual market information as a result of these new anti-discrimination laws.

perhaps appraisers need to archive links to demographic info, and then only reference that link. I note that our MLS often provides Realist data or some source with crime scores, etc. Go figure. Realtors think it important, why cannot appraisers?

 

[Tawfik Ahdab]

The very notion that I should have to reference something that should be available to the reader instantly within the report - especially when that information is taken directly from an authoritative source such as the US census for example - further highlights, the absurdity of the situation we are now in.

But of course TAF’s concern is to opine on the CE versus QE aspects instead of the substance. Useless.

 

[Tiffany Gibbons]

The very notion that I should have to reference something that should be available to the reader instantly within the report - especially when that information is taken directly from an authoritative source such as the US census for example - further highlights, the absurdity of the situation we are now in.

But of course TAF’s concern is to opine on the CE versus QE aspects instead of the substance. Useless.

Well, that's why they get paid the big bucks.

 

[DWiley]

Not only does the omission of some socio-economic information about the market participants and the market area in general diminish the quality of the resulting appraisal report but, beyond that, it impedes the appraiser’s ability to freely research, identify, and report, the demand segment(s) that would be responsive to the real property under study.

I will bite on that. Can you provide examples of the socio-economic information that you believe is so critical for a quality appraisal?

 

[Dublin ohio]

perhaps appraisers need to archive links to demographic info, and then only reference that link. I note that our MLS often provides Realist data or some source with crime scores, etc. Go figure. Realtors think it important, why cannot appraisers?

That information would be useful to a buyer in choosing a neighborhood. If you are appraising a property in neighborhood "X". Those characteristics would be baked into the neighborhood.

 

[Tawfik Ahdab]

Let me give you one example. The residential market in which I specialize is relativly small. There are 9000 presidents in the urban core and another 5000 approximately in the surrounding unincorporated sections of the market area.

The median age in my county is 40.7 years while the median age in my market area specifically is 60.9 years.

This means that much of the population is relatively advanced in age. Much of the housing demand is not due to fundamental factors such as household creation and employment, but rather, is attributable to retiree in-migration.

Thus market demand is dominated by the preferences of older buyers.

These buyers, as they age in place, exhibit a marked preference for one story floorplans and display much more market resistance to two or more level homes.

If I were to do a quality appraisal on a two-story home, I would note that market resistance to such a property would be a factor in the valuation. I would certainly avoid using a one story home comparable unless the floor plan of the two-story home had the main bedroom or suite located on the immediate level at the very least.

No, it’s not my bias or prejudice that causes me to come to these conclusions. It’s an observed market fact, and if as an appraiser, I want to find out why this is so, all I have to do is interview buyers about what they want. In my 31 years of appraisal, that’s what I have done and that’s why I’ve learned what I know and makes me competent to appraise in the market area.

In the example I’ve just given you The functionality of a floor plan is directly related to the mobility and aging of the prospective purchaser.

There are other considerations connected to age that are relevant, such as accessibility/mobility and wheelchair access (that’s a big one around here) that have direct impact on demand for certain housing.

Understanding that and taking that into consideration in the valuation process contributes to the quality of the appraisal because identifying the market segment or segments to which a property may appeal will lead to better judgment in the selection of comparables.

One of the tenets of real estate appraisal is the recognition that different users of real estate may assign a different values to the same property according to their needs, wants, and demands.

Market analysis makes possible a more accurate identification of those users who would most readily accept the features of the real property.

There are other factors that individuate my market area that are also connected to age, such as the preponderance of cash purchases, the high demand for, and premium placed on properties with a three car garage or an RV garage, etc.

These examples are probably too market- specific to be recognized as appraisal factors in most other market areas, but my having knowledge of them certainly contributes to the quality of MY appraisals.

 

[Joe Flacco]

There is no need for demographic discussion. If two-story homes sell for different price compared to one-story homes, then the data would speak for itself. The fact that it is due to older people liking one-level homes is irrelevant.

It might not even be due to old people liking one-level homes. It might be that a 1200 SF one level home also has 1200 SF basement compared to a 1200 SF two-level home which would have a 600 SF basement. It is simply a bigger house.

 

[DWiley]

Let me give you one example. The residential market in which I specialize is relativly small. There are 9000 presidents in the urban core and another 5000 approximately in the surrounding unincorporated sections of the market area.

The median age in my county is 40.7 years while the median age in my market area specifically is 60.9 years.

This means that much of the population is relatively advanced in age. Much of the housing demand is not due to fundamental factors such as household creation and employment, but rather, is attributable to retiree in-migration.

Thus market demand is dominated by the preferences of older buyers.

These buyers, as they age in place, exhibit a marked preference for one story floorplans and display much more market resistance to two or more level homes.

If I were to do a quality appraisal on a two-story home, I would note that market resistance to such a property would be a factor in the valuation. I would certainly avoid using a one story home comparable unless the floor plan of the two-story home had the main bedroom or suite located on the immediate level at the very least.

No, it’s not my bias or prejudice that causes me to come to these conclusions. It’s an observed market fact, and if as an appraiser, I want to find out why this is so, all I have to do is interview buyers about what they want. In my 31 years of appraisal, that’s what I have done and that’s why I’ve learned what I know and makes me competent to appraise in the market area.

In the example I’ve just given you The functionality of a floor plan is directly related to the mobility and aging of the prospective purchaser.

There are other considerations connected to age that are relevant, such as accessibility/mobility and wheelchair access (that’s a big one around here) that have direct impact on demand for certain housing.

Understanding that and taking that into consideration in the valuation process contributes to the quality of the appraisal because identifying the market segment or segments to which a property may appeal will lead to better judgment in the selection of comparables.

One of the tenets of real estate appraisal is the recognition that different users of real estate may assign a different values to the same property according to their needs, wants, and demands.

Market analysis makes possible a more accurate identification of those users who would most readily except the features of the real property.

There are other factors that individuate my market area that are also connected to age, such as the preponderance of cash purchases, the high demand for, and premium placed on properties with a three car garage or an RV garage, etc.

These examples are probably too market- specific to be recognized as appraisal factors in most other market areas, but my having knowledge of them certainly contributes to the quality of MY appraisals.

I asked for a citation where the socio-economic date was critical. Respectfully, what was provided is not such an example.

I have seen a very similar scenario in a condo project near me. It is a large project (over 2,500 units) that was built over a 20 year period. Over the years they changed the floorplan mix over the years, eliminating the multi-story floorplans in favor of one story plans. The agents and the developer both said they did that because they found that although the project was not an age-restricted, the majority of buyers were older buyers with a strong preference for one story living.

While this is good info, I don't see how it is critical in any way to an appraisal in the project. I never referred to any such thing in my appraisal reports in the project near me. All that was necessary for the appraisal was to demonstrate, with data, that one level units had higher prices and shorter marketing times than multi-level units in that project. And the data did clearly show that. No socio-economic info necessary - just sales and listing data.

Taking what you describe as true (and I have no reason to doubt it), I would dare say that by analyzing sales and listing info in your area and reach similar conclusions as you with no socio-economic info at all.

So, again I will ask - can you cite an example where the socio-economic info is actually critical?