The AQB’s third draft

“The Coalition strongly supports eliminating any college degree requirement for Certified Residential and Certified General.”

Washington supported the demonstration report route, Certified General PAREA, removal of minimum experience periods, and optional recurring fair housing education. Its letter endorsed the second draft’s complex-property report requirement, which the third draft later removed.

“Appraisal experience, either single property appraisal or mass property appraisal, should be counted toward experience requirements.”

President Ben Baggett reported that TAC’s executive board and board of directors supported virtually all the second draft’s proposals. TAC also requested recognition of ad valorem experience in jurisdictions that have not expressly adopted USPAP Standards 5 and 6, subject to demonstrated competency and the remaining qualification requirements.

“KCAA supports the Board’s recognition that assessment office oversight can serve as an appropriate substitute for traditional appraiser supervision.”

KCAA supported the second draft and its recognition of mass appraisal work. It asked the AQB to clarify that qualifying experience can include work performed across a team, including analysis, data collection, verification, and other parts of the appraisal process.

“The pathway should also include a structured capstone program incorporating appropriate instructional and experiential elements of PAREA while remaining more limited in scope.”

The Institute recommended limiting entry to applicants from defined adjacent professions. It requested instruction, guidance, access to data and professional tools, and standards for provider oversight. The third draft describes demonstration as an assessment of existing ability and provides no appraisal instruction.

“The proposed Demonstration Appraisal Report Pathway offers a promising alternative by allowing applicants to demonstrate competency through completed work product.”

ASA supported the concept and requested consistent evaluations, qualified reviewers, conflict-of-interest controls, and oversight of participating entities. It also warned that costs and administrative requirements could create new barriers, and requested stakeholder review before the pathway becomes operational.

“ASFMRA supports the use of alternate pathways that would still require the skills associated with a college degree”

ASFMRA proposed additional training or college-level examinations to demonstrate skills in areas such as writing, mathematics, and finance. It supported earlier exam eligibility and recommended extending passing-score validity to three or four years. Its attached survey had 37 responses; the organization explicitly said those responses were not its official position.

“NAA does not believe sufficient justification has been presented to support eliminating the minimum timeframe altogether.”

NAA supported removing degree requirements, adding Certified General PAREA, and strengthening the required curriculum. It asked the AQB to retain minimum experience periods so candidates encounter a range of market conditions and assignments. The third draft retains the proposed removal of those periods.

“There is no information provided on how the AQB-approved entities would determine if the demonstration reports are acceptable.”

NAR requested consistent evaluation standards and recognition of relevant experience from real estate brokerage and other regulated fields. It supported additional pathways and opposed making recurring fair housing education optional. The third draft adds report evaluation requirements and retains the proposal for optional recurring fair housing education.