The National Association of Realtors (NAR) provided comments on The Appraisal Foundation’s Appraiser Qualification Board's (AQB) First Exposure Draft of the Proposed Changes to the Real Property Appraiser Qualification Criteria on March 3.
“NAR is encouraged by the First Exposure Draft of the Proposed Criteria, as it represents a significant philosophical shift away from the rigid, time-based, and supervisor-dependent framework of the existing Criteria, and towards a competency-driven, multi-pathway model,” Keisha Wilkinson, NAR’s senior policy representative on valuation policy, wrote in a post. “This includes broadened experience concepts, greater flexibility in education delivery, and a more modernized approach to workforce entry. However, the draft stops short of formally adopting a full framework to recognize the parallel experience and education that real estate agents and brokers gain every day.”
Credible independent valuations of real property are critical to the health of the overall real estate industry, NAR wrote in a letter to AQB Chair Jerry Yurek.
“NAR strongly supports modernizing the Criteria. Many of the proposed changes reflect long-standing NAR priorities, especially those seeking to expand pathways into the profession, reduce bottlenecks created by the supervisory model and recognize the diversity of valuation activities performed across the real estate industry,” the organization went on to say in the letter. “However, several areas fall short of full alignment with NAR policy, and others would benefit from additional clarification to support implementation and regulator understanding.”
NAR said it supports the Criteria providing broader avenues into the profession, with attempts to expand access by recognizing alternative experience environments and loosening experience sequencing. For example, the proposed Criteria eliminates the requirement for college degrees for all incoming appraisers.
While NAR has no direct policy on the college degree requirement, members have commented that a college degree is not the deciding factor for any person regarding public trust or professional competency.
“NAR believes that competency is a key factor in quality appraisals of real estate, and supports the enhanced focus on competency, with the draft’s emphasis on modernization techniques that demonstrate ability rather than mere accumulation of hours,” the letter to the AQB further stated. “NAR is also pleased to see the retention of required Fair Housing courses, recognizing the importance of federal nondiscrimination knowledge. However, NAR is disappointed that the AQB did not take the opportunity to explicitly recognize the parallel valuation experience that real estate agents and brokers gain every day.”
NAR listed specific areas the AQB should consider changing with regards to parallel professional, non-appraiser experiences including, but not limited to, experience in real estate market analysis, real estate brokerage including evaluating and pricing residential real estate, and other areas.
“The AQB should allow state real estate licensing coursework to satisfy clearly defined portions of the Required Core Curriculum where learning objectives overlap would streamline entrance to the profession by experienced real estate agents and brokers,” NAR added. “NAR encourages the AQB to incorporate the recommendations above to strengthen clarity, promote consistency for state agencies, and fully realize the potential of a competency based, modern appraisal qualification system,” NAR concluded.
To further expound on this parallel experience and education, NAR commented in a letter to AQB chair Yurek about the AQB's Concept Paper: Skills-Based Pathway. In this letter, NAR provided ideas and examples on where valuation-related activities performed by real estate licensees could align with required qualifying appraiser experience.
“NAR appreciates the AQB’s willingness to explore innovative pathways into the appraisal profession and to seek broad stakeholder input on the feasibility, risks, and regulatory implications of such a model,” NAR said in its letter. “The concept paper dealing with Need for a Skills Based Pathway asks whether a skills-based pathway should exist at all and what specific need it would solve. NAR believes the answer is yes. Such a pathway should be developed, but only if designed in a manner that preserves verifiability, standards alignment, evidence integrity and review consistency, as the concept paper identifies. NAR policy recognizes that the housing market continues to face shortages of available appraisers. Parallel workforce shortages also exacerbate concerns about diversity, access and geographic coverage. NAR therefore supports well-constructed alternative pathways that responsibly expand the pool of qualified appraisers.
“However, as the concept paper notes, the challenge is significant: a skills-based model must remain compatible with the Uniform Standards of Professional Appraisal Practice (USPAP) framework and state regulatory oversight,” NAR went on to say in its letter. “While NAR does not have policy on the structure of a feasible model, Realtors appreciate the ASB’s effort to outline model requirements that expand entry opportunities, maintain standards, ensure enforceability, and provide regulators with auditable, reviewable materials. This is achievable, but only if the AQB grounds such a pathway in a defined standards framework, not in isolated technical tasks.”
NAR concluded in its comments that a well-designed pathway that integrates education equivalency, parallel valuation experience, and USPAP anchored demonstration reports can expand access without compromising public trust.