Lest we all get too wrapped up in who was denied entry to the USPAP Instructor Certification course, I'd like to clarify what the course is and what it isn't. Please note that these are my own opinions and I may very well be alone in holding them.
As far as I can tell, the USPAP Instructor's Certification course was developed by The Appraisal Foundation to present the underlying theories of the USPAP to those individuals who have experience in teaching the subject to others. The reasoning being that if instructors understand the underlying theories, they can structure their lessons accordingy and without going off in wild tangents, as has happened in the past. The Appraisal Foundation has a student manual and companion instructor's manual that is supposed to be used by instructors for all future USPAP instruction. The AFs intention is that an instructor who has taken and passed the certification course and is using the AF's manuals will not be able to deviate from the philosophies and intentions used to develop and maintain the USPAP. The course is intended to further the goals of more standardized instruction by instructors, and eventually, more standardized understanding anbd practice by the appraisal community at large.
The standardization of instruction is the primary purpose of the course. In my opinion (I could be wrong about this), one of the secondary purposes is to weed out those individuals who might have been teaching the course but cannot come to terms with The Appraisal Foundation's philosophies and intent. The manner of testing, which is based on multiple choice questions with more than one right answer but is counting as correct only the most complete answer, is apparently intended to weed out those individuals who are unable to reconcile the underlying theories with the examples provided. I've heard varying pass ratios for the course, but suffice it to say that The Appraisal Foundation anticipates a significant percentage of the participants will fail the test. That was certainly true in the case of the class I was in. I was very surprised to learn of a couple of individuals whom I know to be pretty smart and very experienced, but ended up failing the test. Provisions were made at the very beginning for retaking the test, before it had even been adminstered the first time. The 109 certified instructors on the list now do not represent the total number of people who have taken the course.
The USPAP Instructor's Certification Course is not intended to teach the practical applications of USPAP. In fact, the majority of the practice examples in the course are structured to help instructors differentiate between different theories, rather than learning practical applications. Every 7-hour USPAP update course I ever taught had far more practical applications in it than the 16-hour Instructor course. IMO, the average appraiser or state regulator taking the course will not have a better understanding of the practical USPAP applications, and in fact, might just find it frustrating for that omission. I think state regulators would be better equipped to enforce the USPAP if they took and understood a regular USPAP update course as taught by a good instructor.
As for state regulators not taking the test, I have conflicting opinions on that subject from a personal viewpoint. On the one hand, I think all of the state regulators and investigators should take some instruction and have to pass a test as a means of demonstrating a minimum level of understanding. Merely auditing the class does not guarantee any level of understanding, but it might infer some competency where none rightfully exists.
The instructor participants sitting in the course will have a lot of motivation to do the extra studying and to actively participate in the course because they have to pass the test. Those individuals who are merely auditing the course with no intention of taking and passing the test will not have as much motivation to understand the material. I don't like the idea that a state regulator who has been present at the course but perhaps not an active or concientious participant might claim a level of expertise that is completely unwarranted. Of course, since they haven't taken the test, they shouldn't be claiming the course anyway. I would advise any appraiser who gets jammed by a state regulator who claims USPAP expertise by virtue of taking the course should ask whether the regulator passed the test. No test, no demonstrated competence in the subject.
In an ideal world, The Appraisal Foundation would develop and instruct a separate state regulator's course (probably on a regional basis), for which the participants would be required to take a test and pass it in order to claim the course. This course would be different from the instructor's course in that it would be more oriented toward enforcement issues the state boards face in their laws and regulations on issues that are defined and addressed in the USPAP. This would also give the state boards yet another opportunity to interact directly with The Appraisal Foundation, as some states are claiming they don't currently have enough access. Obviously, there would be no need for the general public or USPAP instructors to take that course since it isn't oriented toward them. In lieu of a specialized regulator's course, state regulators should take a regular USPAP update (as taught by a certified instructor) and pass the same test as appraisers in order to claim some level of competence in the USPAP. And that test should be relatively straight forward, not honed so finely that the correct answer is the most complete of four right answers.
So I guess that what I'm trying to say is that unless someone already has some experience teaching the USPAP and other appraisal courses to their peers, they aren't missing much in not taking the Instructor's Certification Course. But tht's just my opinion.
George Hatch
