Experience Requirements Reduced

Experience Requirements Reduced, College Degree Still Required for CGSometimes the only substitute for experience, …is more experience.

Dear Mr. Traynor:

The American Guild of Appraisers has long been on record in opposition to the original requirement for a college degree to become any level of real estate appraiser. This was never a requirement of Congress at all, but rather one developed by the AQB over time.

While we are pleased AQB has abandoned the college degree at the licensed and residential certification levels, we are disappointed to see it is still being proposed at the general certified level.

We repeat for the record; there is nothing involved in commercial and industrial appraisal that requires a degree unless AQB is admitting that its basic general certification testing requirements & tests are deficient. Your continued insistence on a college degree is nothing more than elitism.

We are also particularly concerned that AARO was among your consulting groups. Allowing AARO to provide input circumvents not only the will of the United States Congress but also that of the individual states. It is inappropriate for state bureau employees to circumvent their legislators to effect changes in the real estate profession.

Instead of requiring a degree for general certification, increase the testing requirements. If that is not enough, then require that continued education for general certified appraisers include a certain number of hours in advanced appraisal techniques.

Many of us would prefer to take new, advanced courses for credit rather than the same old repetitive courses designed for residential appraisers. Direct your focus in this area instead of the unnecessary degree requirement and meaningful advanced education will result.

By requiring a college degree, you impede the ability of existing general certified appraisers to relocate, or to become general certified in new states. So, when many of us reach a point in our lives where we would like to relocate to another state for whatever reason, we cannot do so, and the only other option is to give up appraising. At a minimum accept the same experience credits the federal civil service does. Two years related experience to one-year educational requirement.

AQB has done more to create the so-called appraiser shortage over the past fifteen years than the recession; HVCC and abuses of AMCs combined have. This is just one more example.

The American Guild of Appraisers also opposes reducing the experience requirements by any amount. There is no need for it other than what we have been told in public by TAF is an accommodation for new college grads that can’t be bothered to take three to five years in order learn their new chosen profession. It is not the function or obligation of TAF or AQB to ease entry for a selected class of applicants only.

Regardless of one’s background, it still takes a good five years to become proficient as an appraiser. Simple competency may be attained in a shorter period, but certainly not all-around proficiency. There is a reason lenders normally require five or more years for new appraiser panel applicants.

It’s ironic that TAF/AQB and others talk about “lowering standards” if the degree requirement is removed, but no such perception of lower standards is considered to result if the experience requirements are lowered. I have not heard one appraiser demand this over the past ten years. Not one.

There are no practicum courses that will give a new appraiser three to five years equivalent experience. Sometimes the only substitute for experience, …is more experience.

Respectfully submitted

Michael F. Ford
American Guild of Appraisers
Chairman NAPRC /V.P. Special Projects
Mobile (714)366-9404
AGA Office 301-377-0099
m…@mfford.com or

The above letter dated January 11, 2018, was addressed to Joseph C. Traynor, Chair of the AQB, regarding Proposed Changes to the Real Property Appraiser Qualification Criteria
Michael Ford
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Michael Ford

Michael Ford

Over 28 years appraising all property types and interests, in Southern California real estate. VP/Chairman National Appraiser Peer Review Committee, American Guild of Appraisers, #44OPEIU/AFL-CIO. - Michael Ford on e-AppraisersDirectory

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18 Responses

  1. Jonathan Smith on Facebook Jonathan Smith on Facebook says:

    Patricia Henson Smithh

  2. Avatar Eric West says:

    Good letter Mike. IMO, if you want to become an appraiser, you have to WANT to become an appraiser & do the time. It shouldn’t be an “easy” road.

  3. Avatar wontobey says:

    The dumbing down of experience is plain dumb!

  4. Avatar A. Brown says:

    Reducing experience will only be a reasonable accommodation to some within the industry. If AQB was concerned for public trust, they wouldn’t consider any reductions. It looks like REVAA is giving them an earful.

    • …and Corelogic, though I suspect most of this originates inside TAF itself.

      The original FIRREA and TAF/AQB appraiser requirements were fine. They reflected the will of the Congress.

      Everything since then has largely reflected with will and desire of TAF to continue to be able to offer its leaders high paid jobs after they leave government employment. They have gone very, very far astray from what they were charged to do.

      “For the People.” Sure.

  5. Avatar Diana N. says:

    They keep making it easier and easier for me to decide to retire, if you total up all the class hours I’ve had over the last 40+ years, I should have the equivalent  to 5 Doctorates and a few Masters Degrees, but they still only want to pay peanuts for experienced appraisers and quality reports.  

  6. Avatar Rhonda Ward says:

    Very well written. I have been a Certified Residential Appraiser for 16 years.  I have some college, but not a degree.  I wanted to be an appraiser, took the classes, took the exams, did the apprenticeship and training hours and love my profession.  I agree with your letter.  If the college requirement was in place 15+ years ago, I would venture to say that over 50% of the current appraisers would not qualify.   

  7. Avatar Rob says:

    Nothing much to worry about either way. Here in Westchester County, NY, just north of NYC and a population of about 1 million, I bet you can count the number of residential trainees on one hand. Nobody is training anybody because in general fees are too low, the volume of work is unknown, and the payoff is you’ve trained your future competition.

    Vast majority of appraisers (like 95%) are over 55. In 15 years I’m not sure what will happen.

    • Avatar Bill Johnson says:

      Every area is different Rob. I work one county (San Diego) where there is 3.3 million people and just over 950+/- appraisers (ALL WITHIN 30 MILES OF ME). If you go out a few hundred miles (a stretch) and include Southern CA I would bet I’m perhaps 1 of 5,000 (?). In theory, if I work to the extreme North or South of the county, perhaps 500+ appraisers are locationally closer than me. Although my state has 10,592 active licensees (01/16/2018 / BREA Licensing Stats), perhaps the icing on the cake is that we are losing by my count +/- one appraiser per day. At that rate, in 29 years the last appraiser will be gone.

    • Rob, I suspect you are right in your area, but have you ever considered that training appraisers is also one of the best sources of higher paying fee appraisals you can get? Almost all of my business is now referral work. Usually from someone I either trained, or developed a friendly competitor relationship with.

      I have more than 30 years real estate experience. I’m sure there are those with even more experience, but it is not my trainees. I have always wanted them to be the best appraisers they can be. Quality over quantity. Anticipate the logical questions your reporting of facts raises, and then attempt to answer those within the report (within reason). One of the things they learn are their own license level limitations and what happens when appraisers are tempted to exceed those limits. Trying to teach another forces me to stay sharp and advance my own education.

  8. Avatar Fritz Vogel says:

    Again, very well written. You can tell you have more than “skin in the game” at this point, it is your LIFE. I hate to break the happy bubble but I disagree. In your instance, your years in the Biz cannot be discounted and you will be “grandfathered” to do what you wish. I agree that there are NO trainees knocking on our doors, why would they, this Profession sucks. yes there WILL be a shortage, 10-15 years down the line. There is no one in the pipeline. Not our problem. We are here now, Licensed and/Certified and able to make $$$$. In the 5-15 year future, make LOT’s of money (given the current trend) due to the lack of replacements. Why complain?I wish that a BA/BS degree become a threshold in the very near future. We are crapped on by lesser (UW, Processors, LO’s,  etc. that Probably don’t have any degree on a regular basis for nonsense. Why NOT improve our “Rating”. I can’t see any reason.  

    • Baggins Baggins says:

      We the People of the United States, in Order to form a more perfect Union, establish Justice, insure domestic Tranquility, provide for the common defense, promote the general Welfare, and secure the Blessings of Liberty to ourselves and our Posterity…..

      Checks and balances my friend, checks and balances.  The appraisers position is much more important than many realize.  In the market heat over several years I brushed off a few dozen hopeful cold trainee solicitations.  I can’t untrain an advocate.  I can only mentor non advocacy within a person with an already open and fair mind.  No college could keep up with the changing curriculum which is government bureaucracy in real estate. You just have to keep up as you go. 5000+ training hours and no degree, that sounds better.

  9. Avatar Kent says:

    I was unaware they removed the requirement for certified appraisers to have a degree.  Is that true?

    • Kent, its not a ‘done deal’ yet. My understanding is the fourth exposure draft proposes elimination of degree requirement completely at license level. My belief is that they are now considering elimination at the residential certified level but not at the general certified level. Same arguments that applied at all other levels still apply and GC level.

      With all the parsing of language to circumvent Dodd Frank; we have FIRREA/USPAP that depends on appraisers rather than misleading forms, form designers that embed false verbiage in spurious report that appraisers reports using those forms will be complaint; general certified appraisers who also are in the business of selling regression software or regression courses  are no longer content to merely say RA is just another tool in the box. They now suggest or infer strongly that anything other than RA is unreliable. Legislators that pass protective measures with no enforcement mechanisms.

      We don’t have a dearth of degrees. We have too much influence from liars, cheats and thieves. Some (not all)  who have degrees and have only learned to be better liars, cheats and thieves.

  10. Avatar Jack Of All Trades says:

    I think the AQB is in bed with the AMC’s, weren’t they lobbying this to the AQB for while? If AMC’s really wanted the CG level without a college degree then it probably would happen, just my 2 cents ……good article. 

    • Retired Appraiser Retired Appraiser says:

      AMCs were certainly for the repeal of the requirement but in all fairness the repeal was necessary to correct a poor decision they made. They move at the speed of the Titanic when it comes to turning around. They made the “genius” decision when the appraisal market was red hot and everyone wanted in, yet implemented it just as Cuomo & Company (HVCC) wiped out the appraisal business.


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Experience Requirements Reduced

by Michael Ford time to read: 3 min