Appraiser licensing criteria: Update of proposed changes - by Darwin Werthessen

As many real estate appraiser trainees are aware, there are proposed changes to the state’s licensing criteria working its way through the legislative process. This article focuses on only those changes to the certified general appraiser criteria, which are relevant to commercial real estate appraisers. Those changes to the residential appraiser classifications (certified residential and licensed residential) are not covered here. 

For historical perspective, on February 1, 2018, the Appraisal Qualifications Board (AQB) adopted sections 1, 2, and 4 of the Fourth Exposure Draft of Proposed Changes to the Real Property Appraiser Qualification Criteria. These changes affected licensed residential and certified residential as well as certified general licensing requirements for appraisers across the nation. Many states adopted these changes to their individual state licensing requirements once they became effective on May 1, 2018, including New Hampshire, Vermont, and Rhode Island. Individual states retain the right to keep more stringent licensing standards at their discretion.

The proposed changes will reduce the time requirement from 30 months of experience to 18 months. The applicant will still be required to attend 300 hours of primary education comprised of the 10 standard courses and one elective as well as being required to log 3,000 hours of experience. Only the time frame in which these requirements are completed will be reduced. The change of the time requirement is logical as trainees working full-time (40 hours per week) typically compile the requisite hours (3,000) in an 18-month time frame. 

Massachusetts, however, has legislation which prevents the seamless incorporation of the AQB’s standards into the state’s licensing criteria. The need to update and remain current was not lost on the state’s Board of Real Estate Appraisers, though. In late 2018, the Massachusetts Board of Real Estate Appraisers (MBREA) accepted motions to begin the process of changing the state’s licensing criteria to become more in line with the AQB’s stated suggestions.

At the most recent public meeting of the MBREA on February 21, the status of the proposed changes was updated. According to the board’s legal counsel, the draft proposal from the secretary of state’s office is close to completion and approval of such is anticipated in late Q1 2019. 

As required, a public session for review and comments will be held before the draft proposal is presented to the MBREA. Presentation of the draft is slated for the next full meeting of the board on April 18. Upon acceptance by the board, provided there are no changes to the draft document, the proposed legislative changes will be sent back to the secretary of state’s office for publication. 

Publication by the secretary of state’s office takes place every two weeks. At present, the most realistic scenario for the proposed changes becoming effective is late Q2 2019. It should be noted that delays are possible, and the dates are very much undefined at this stage. Trainees, and supervisors, across the state remain hopeful the progress will remain on track and be completed before Q3 2019.

While it is impractical to survey the state’s real estate appraiser trainees to understand where individuals are in their progress, it is likely the proposed changes will create a glut of applicants for licensure. This will potentially create a backlog of applicants and the board will need to prepare in the event a backlog ensues.

The MBREA should be commended for pursuing the proper channels to address the changes to the licensing criteria. This will keep Massachusetts up-to-date with the AQB, the Appraisal Institute (AI), and the rest of the nation while relieving subsequent trainees of the additional time requirements.

Relatedly, the Appraisal Institute is again sponsoring a series of courses providing the requisite primary courses for licensure. Those trainees in need of fulfilling these courses are encouraged to visit the Appraisal Institute’s Massachusetts and Rhode Island Chapter webpage for current listings and offerings. 

Darwin Werthessen is a valuations analyst at Integra-Boston.