The FREAB has too much time on their hands!

[incognito]

Well, have you seen this? According to the August 2011 East Florida Chapter Appraisal Institute newsletter (you don't really think the state would let us know, do you?), the FREAB is proposing to eliminate nearly ALL of the formerly acceptable methods of presenting your license/certification.
For me, I have always used St.Cert.Gen. REA RZxxx. Well, that is no longer going to be acceptable. In fact, it looks like there will only be one or two approved methods of properly writing your license/certification, depending on your level.

Here is the best part: They calculated that it would only cost US, the appraiser, $25 each to implement this change! Hmmm, new business cards, new signage, new ads, new letterhead, not to mention the hours of re-issuing my "newly formatted" license information to my 200 or so clients.

Don't they have better things to do?

This is the text of the proposal. It is not copyrighted or personal, and is public record:

Notice of Proposed Rule

DEPARTMENT OF BUSINESS AND PROFESSIONAL REGULATION
Florida Real Estate Appraisal Board
Rule No. : RULE TITLE :
61J1-7.001: Display and Disclosure of Registration, License or Certification Designation
PURPOSE AND EFFECT: The Board proposes the rule amendment to clarify what designations or abbreviations denoting licensure may be used on appraisal reports.
SUMMARY: The language concerning what designations or abbreviations denoting licensure on appraisal reports will be clarified.
SUMMARY OF STATEMENT OF ESTIMATED REGULATORY COSTS: Have an adverse impact on small business, nor will the proposed rule likely increase directly or indirectly regulatory costs, including transactional costs, in excess of $200,000 in the aggregate within one year or $1 million in the aggregate wi thin 5 years after implementation of the rule. Therefore, it has been determined that the rule does not meet the threshold for ratification by the Legislature. The following is a summary of the SERC:
• A total of 7,652 appraiser licensees will be affected by the rule amendment.
• All Registered Trainee Appraisers, Licensed Appraisers, Certified Residential Appraisers, and Certified General Appraisers will be required to update their advertising media to reflect the simplified abbreviation of their designation.
• There will be no additional cost to the department for implementing the proposed rule.
• There will be no cost to any other state and local government entities of implementing the proposed rule.
• An estimated number of the small businesses that would be subject to the rule are more than 5,000.
• Analysis of impact on small business: 7,652 appraiser licensees with a cost of approximately $25.00 per licensee for a total of $191,300, a one-time expense to current licensees.
• No small county or small city will be impacted by the proposed rule.
Any person who wishes to provide information regarding a statement of estimated regulatory costs, or provide a proposal for a lower cost regulatory alternative must do so in writing within 21 days of this notice.
RULEMAKING AUTHORITY: 475.614 FS.
LAW IMPLEMENTED: 475.622 FS.
IF REQUESTED WITHIN 21 DAYS OF THE DATE OF THIS NOTICE, A HEARING WILL BE SCHEDULED AND ANNOUNCED IN THE FAW.
THE PERSON TO BE CONTACTED REGARDING THE PROPOSED RULE IS: Juana Watkins, Acting Director, Division of Real Estate, 400 West Robinson Street, Hurston Building, North Tower, Suite N801, Orlando, Florida 32801

THE FULL TEXT OF THE PROPOSED RULE IS:
61J1-7.001 Display and Disclosure of Registration, License or Certification Designation.
(1) No change.
(2) The following designations or abbreviations shall be used:
(a) “State-registered trainee real estate appraiser”, “registered trainee” or “Ttrainee RI###.”
(b) “State-licensed real estate appraiser”, “state-licensed r.e. appraiser”, “state-lic. r.e. appraiser”, “state-lic. r.e. appr.” or “St.Lic.REA” or “Licensed RH###.”
(c) “State-certified residential real estate appraiser”, “state-certified residential r.e. appraiser”, “state-certified residential appraiser”, “state-certified res. appraiser”, state-cert. res. appraiser”, “state-cert. res. appr.” or “St.Cert.Res.REA” or “Cert Res RD###.”
(d) “State-certified general real estate appraiser”, “state-certified general r.e. appraiser”, “state-certified general appraiser”, “state-certified gen. appraiser”, state-cert. gen. appr.” or “St.Cert.Gen.REA” or “Cert Gen RZ###.”
(3) No change.
Rulemaking Specific Authority 475.614 FS. Law Implemented 475.622 FS. History–New 10-15-91, Formerly 21VV-7.001, Amended 10-29-98, 2-12-03, 2-16-04,_______.

NAME OF PERSON ORIGINATING PROPOSED RULE: Florida Real Estate Appraisal Board
NAME OF AGENCY HEAD WHO APPROVED THE PROPOSED RULE: Florida Real Estate Appraisal Board
DATE PROPOSED RULE APPROVED BY AGENCY HEAD: December 7, 2010
DATE NOTICE OF PROPOSED RULE DEVELOPMENT PUBLISHED IN FAW: November 24, 2010

I will protest this change...

 

[incognito]

It gets better! The new UAD spec REQUIRES that your license be entered on the appraisal in the EXACT format that your license appears in the Appraisal Sub Committee (ASC) registry. Guess what, mine is RZxxx in the ASC registry, yet that IS NOT a State of Florida approved format! Way to go guys and gals...

 

[Couch Potato]

Too late.

The 21 days to request a hearing have already passed. The new rule is effective 7/17/2011.

61J1-7.001 Display and Disclosure of Registration, License or Certification Designation.

(1) All appraisers registered, licensed or certified pursuant to Part II, Chapter 475, Florida Statutes, shall disclose and display the appropriate designation in writing in all appraisal reports which are signed by the appraiser. Disclosure of the appropriate designation is required even if the appraisal performed is outside of the scope of registration, licensure, or certification as an appraiser.

(2) The following designations or abbreviations shall be used:

(a) “State-registered trainee appraiser” or “Trainee RI###.”
(b) “State-licensed real estate appraiser” or “Licensed RH###.”
(c) “State-certified residential real estate appraiser” or “Cert Res RD###.”
(d) “State-certified general real estate appraiser” or “Cert Gen RZ###.”
​

(3) No other designation or abbreviation thereof shall be used. The above designations and abbreviations may be used without regard to capitalization or punctuation.

Rulemaking Authority 475.614 FS. Law Implemented 475.622 FS. History–New 10-15-91, Formerly 21VV-7.001, Amended 10-29-98, 2-12-03, 2-16-04, 7-17-11.

 

[Couch Potato]

It gets better! The new UAD spec REQUIRES that your license be entered on the appraisal in the EXACT format that your license appears in the Appraisal Sub Committee (ASC) registry. Guess what, mine is RZxxx in the ASC registry, yet that IS NOT a State of Florida approved format! Way to go guys and gals...

That is not a problem. There is not a restriction on displaying your license number alone. The restriction is on words and abbreviations describing you. Somewhere you must indicate “State-certified general real estate appraiser” or "Cert Gen" followed by your license number to describe who you are.

 

[Wm. Hattaway]

Having sat in on several FREAB meetings, one of the recurring violations among appraiser is how they sign the appraisals. Hopefully this will reduce violations as the appraiser now only has 2 options.

 

[Couch Potato]

It might reduce them in the long run, but it will certainly increase them for the last two weeks of July. Fines for violations on reports in that timeframe looks like a surefire revenue stream to me.

 

[nauthead]

Was this change initiated by the business card companies? I have over 1,000 cards that will be useless in less than a week.

 

[Pittsburgh Pete]

Having sat in on several FREAB meetings, one of the recurring violations among appraiser is how they sign the appraisals. Hopefully this will reduce violations as the appraiser now only has 2 options.

I pray that my state board has bigger fish to fry than slapping wrists for such an innocuous infraction. Sounds to me like the FL state board has spent too much time in the midday sun.

 

[Francois K. Gregoire]

Was this change initiated by the business card companies? I have over 1,000 cards that will be useless in less than a week.

From what I hear, it was done in response to whines from some AMCs and maybe the GSEs. Had to do with the size of the field and inability to include the approved designations within the character count allowed.

Since licensing and certification became law, I have never used an abbreviation for my designation. The way I read state law, I might still be in the clear.

475.622 Display and disclosure of licensure, certification, or registration.—
(1) Each appraiser registered, licensed, or certified under this part shall place her or his registration, license, or certification number adjacent to or immediately beneath the designation “state-registered trainee real estate appraiser,” “state-licensed real estate appraiser,” “state-certified residential real estate appraiser,” or “state-certified general real estate appraiser,” or their appropriate abbreviations as defined by rule, as applicable, when such term is used in an appraisal report or in a contract or other instrument used by the appraiser in conducting real property appraisal activities. The applicable designation shall be included in any newspaper, telephone directory, or other advertising medium, as defined by rule, used by the appraiser.

 

[444nutman]

I am glad I check out AF or I would have never known. It would make more sense to impliment changes the day after our licenses expires. That way you could get the information when you take continuing ed. I called 2 other appraisers who I talk to on a constant basis and neither one of them knew about it either.

The only bonus is I am down to about 50 business cards, so I had to get new ones anyway.