NY DOS Audit

[Brian Hannan]

I am a non-practicing, Certified Residential Appraiser. On 03/10/2024 my license expired. This year I took, what I thought, was all the necessary CE courses (28 + 14) and renewed my license. I received a Notice of Audit from DOS and emailed the course certificates. It appears I was misinformed about the requirements. Per DOS, I need an additional 14 hours. I received different answers when calling Division of Licensing and the online course provider provided me with this information: Since your license expired on 03/10/2024 and today is 11/19/2025, that’s about 1 year and 8 months past expiration. You do not need another 14 hours for the second year because you haven’t reached a full two-year lapse yet. Note: It turned out to be later than 11/19/2025 however still under 2 years.
Copied from: dos.ny.gov/license-renewal
Please note that you must complete an additional 14 hours of approved continuing education for each year that has lapsed if you renew 185 days after the expiration date of your license.

I received a Consent Order from DOS that I am concerned about signing. The opening paragraph states, in short, that I hereby enter a plea of no contest that I failed to complete the required CE courses prior to filing my renewal for the period of 03/11/2022 - 03/10/2024. This is not true. I did complete these courses and emailed the certificates. I questioned this discrepancy and was told that this is the term before my license lapsed.

Key points in the Consent Order: I waive my rights. I complete 14 hours. Pay $250. Should I sign this?

Any feedback is greatly appreciated.

 

[Alsie35]

Are you renewing it in NY so you can waive into Florida as an appraiser? I cannot comment on NY as I was never licensed there and am unaware of the process.

As a general rule however I would be as leery as you are about signing something that is in error. Does it make any practical difference if it allows you to renew and (I am presuming) waive into Florida? I cannot answer that question as I do not know all the facts or requirements of the states involved.

(What you do NOT want to happen is to agree that you did something irregular - when it is untrue - and then have it create a question or obstacle to getting your license in another state - if that is what you are doing.)

 

[Brian Hannan]

Are you renewing it in NY so you can waive into Florida as an appraiser? I cannot comment on NY as I was never licensed there and am unaware of the process.

As a general rule however I would be as leery as you are about signing something that is in error. Does it make any practical difference if it allows you to renew and (I am presuming) waive into Florida? I cannot answer that question as I do not know all the facts or requirements of the states involved.

(What you do NOT want to happen is to agree that you did something irregular - when it is untrue - and then have it create a question or obstacle to getting your license in another state - if that is what you are doing.)

Hello Wayne. Thank you for replying. Sorry for the confusion. I have not been on this site for quite some time and didn't realize I have my state listed as Florida. I need to change that to NY.

 

[Brian Hannan]

Hello Wayne. Thank you for replying. Sorry for the confusion. I have not been on this site for quite some time and didn't realize I have my state listed as Florida. I need to change that to NY.

They are correct regarding the additional 14 hours needed however the first paragraph of the Consent Order doesn't make sense and I feel that I'm not getting a good, clear explanation about it.

 

[Alsie35]

Hello Wayne. Thank you for replying. Sorry for the confusion. I have not been on this site for quite some time and didn't realize I have my state listed as Florida. I need to change that to NY.

Err ... I'm not "Wayne" - (but I'll assume you thought my first name was "John" and count it as a high compliment. )

As far as your second post ... a saying comes to mind: "You can't fight City Hall". Make sure you carefully consider what is the most practical and useful action for YOU to take. Not every hill is the "hill is to die on". Good luck.

 

[Brian Hannan]

Err ... I'm not "Wayne" - (but I'll assume you thought my first name was "John" and count it as a high compliment. )

Oh No! Sorry about that. The email says Wayne@

 

[JTip]

Take the 14 hours. Pay $250. Life resumes.

 

[Brian Hannan]

Take the 14 hours. Pay $250. Life resumes.

Yes. I am going to do the 14 hours this weekend. My concern with signing the Consent Order is that it is not correct. The opening paragraph is a false statement.

 

[sputnam]

I am a non-practicing, Certified Residential Appraiser. On 03/10/2024 my license expired. This year I took, what I thought, was all the necessary CE courses (28 + 14) and renewed my license. I received a Notice of Audit from DOS and emailed the course certificates. It appears I was misinformed about the requirements. Per DOS, I need an additional 14 hours. I received different answers when calling Division of Licensing and the online course provider provided me with this information: Since your license expired on 03/10/2024 and today is 11/19/2025, that’s about 1 year and 8 months past expiration. You do not need another 14 hours for the second year because you haven’t reached a full two-year lapse yet. Note: It turned out to be later than 11/19/2025 however still under 2 years.
Copied from: dos.ny.gov/license-renewal
Please note that you must complete an additional 14 hours of approved continuing education for each year that has lapsed if you renew 185 days after the expiration date of your license.

I received a Consent Order from DOS that I am concerned about signing. The opening paragraph states, in short, that I hereby enter a plea of no contest that I failed to complete the required CE courses prior to filing my renewal for the period of 03/11/2022 - 03/10/2024. This is not true. I did complete these courses and emailed the certificates. I questioned this discrepancy and was told that this is the term before my license lapsed.

Key points in the Consent Order: I waive my rights. I complete 14 hours. Pay $250. Should I sign this?

Any feedback is greatly appreciated.

You are non practicing. Sounds like retaining your appraiser credentials is a more a matter of 'what if' or of pride. You have to make your own decision... if it were me, I'd be chatting with a lawyer about it.

 

[Brian Hannan]

You are non practicing. Sounds like retaining your appraiser credentials is a more a matter of 'what if' or of pride. You have to make your own decision... if it were me, I'd be chatting with a lawyer about it.

Yes, I would say it's a matter of what if. As you know, getting certified is a long haul. Thank you for replying.