Okay, but in counterpoint I was criteria of the previous increase in some of these qualifications in the first place without any evidence that "unqualified" was causing any significant problems WRT appraisal quality. I don't believe "unqualified" has ever been the reason for appraisals not meeting SR1/SR2.
If someone was trained - and tested - on how to develop and apply market conditions adjustments during the shake-n-bake Appraisal 101 course, but they later "forgot" how to do that via disuse that is not an example of unqualified being the reason for the failure. It happened because the individual didn't work to their own previously-demonstrated competency .
The thing about minimum standards is that they have to be set at a point that we can reasonably expect everyone to meet all or almost all the time and under almost all valuation scenarios relative to the scope of practice at a particular licensing level. For example, we can't make Berts' plan the universal minimum requirement for all SFR work unless/until we can expect that app to work virtually all the time. AND unless our users will have that level of confidence in its credibility, sufficient to continue using appraisers.
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I agree that the AQBs actions with PAREA will serve to keep the lenders oversupplied with appraisers but there were other parties besides the lenders and AMCs who have been talking about running out of appraisers. The Appraisal Institute being among them. That discussion has been going on for years.
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