Introduction

Proposed Changes to the Real Property Appraiser Qualification Criteria (Criteria)
In this First Exposure Draft, the AQB is proposing two types of changes to the Criteria:
  1. Adding Qualifying Education (QE) and Continuing Education (CE) requirements for course work in valuation bias and fair housing laws and regulations.
  2. Revising and updating the name of the current 7-Hour National USPAP Update Course
 
Adding Qualifying Education and Continuing Education requirements for course work in valuation bias and fair housing laws and regulations.
Under the provisions of Title XI of the Financial Institutions Reform, Recovery, and Enforcement Act of 1989 (FIRREA), the Appraiser Qualifications Board (AQB) establishes the minimum education, experience, and examination requirements for real property appraisers to obtain a state license or certification as well as Supervisory Appraiser requirements. The AQB regularly solicits and receives comments and suggestions for improving the Real Property Appraiser Qualification Criteria (Criteria).

Concerns relating to discrimination, fair housing law violations and real property appraisals have become important topics across the housing industry and the appraisal profession. While these are complex issues, many of which go beyond the scope of the Criteria, a wide range of stakeholders have urged the AQB to require, as part of both an appraiser’s qualifying and continuing education, courses on valuation bias and fair housing laws and regulations.

For example, one major stakeholder includes the White House task force known as PAVE (Property Appraisal and Valuation Equity). PAVE issued an action plan in early 2022 that includes recommendations to the AQB to add education on these topics for all credentialed and aspiring appraisers.
Considering this request, and based on feedback from others, the AQB felt it important to reach out to all stakeholders to explore adding these types of requirements to the Criteria.

As a first major action item, the AQB held the Forum to Explore Education Requirements: Fair Housing Laws and Valuation Bias Education (Forum) on September 12, 2022. At that forum, the AQB and the public heard from federal agencies, state appraiser regulatory agencies, professional appraiser organizations, education providers, and consumer, civil rights, and fair housing advocacy groups on the topic of requiring valuation bias and fair housing laws and regulations education for real property appraisers.

As a result of the participants on that Forum giving the overwhelming feedback that topics of valuation bias and fair housing laws and regulations should be required education for all appraisers, the AQB then held a working group meeting with state appraiser regulatory agencies, professional appraiser organizations, education providers, appraiser coalitions, and consumer, civil rights, and fair housing advocacy groups to ask questions and receive feedback on what exactly these education requirements should contain.

Based on the comments received at the Forum, in the stakeholder meeting, and other feedback channels, the AQB is issuing the Exposure Draft contained herein.  

Revising and updating the name of the current 7-Hour National USPAP Update Course and the 7-Hour Instructor Recertification Course. 
The AQB is also proposing to update the name of the 7-Hour National USPAP Update Course to “7-Hour National USPAP Continuing Education Course.” The AQB is also proposing the removal of the “7-Hour” from the title of the 7-Hour Instructor Recertification Course. The proposed change better reflects the purpose and content of the course.
Timing of Proposed Changes
For the purpose of this First Exposure Draft, these changes assume a new Criteria (where these proposed changes to be adopted at the public meeting on March 22, 2023) would become effective January 1, 2025.

It is necessary to allow sufficient lead time to state regulatory agencies when increases in the minimum Criteria are adopted, as each state has different regulatory processes, some taking over one year to complete.  Sufficient lead time gives states the time needed to implement these types of Criteria changes. However, states can implement these changes prior to the effective date of the Criteria if they so choose.

On behalf of the AQB, thank you for taking time to review and respond to this exposure draft.

If you have any questions, please contact the Board at AQB@appraisalfoundation.org.

Brad Swinney
Chair, Appraiser Qualifications Board

You can upload a pdf of your comments, comment on the entire Exposure Draft, or comment on each section.

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