This Blog post is a little longer than most I write. I would hope that you take the time to read it in its entirety and then make your own decisions. Thanks again for following me and my writings.
It is no secret that the real estate appraisal profession has recently been in the crosshairs of many organizations, lenders, government entities, and homeowners. While many topics are being discussed, I will focus on the one issue that seems to keep repeating itself day in and day out. That topic is the lack of appraisers entering the field. Many people seem to think that this is a problem with no solution. I am here to tell you that there is a solution. That solution is appraiser trainees
For years now and especially during this past year, when the market went crazy, Lenders, Tech Companies, Agents, and more were out in full force on every platform, complaining that there was a lack of Real Estate Appraisers across the country. The real estate appraisal profession has been dealing with this issue and narrative for years and to no fault of their own. It’s a product of many factors that many do not know about, which I hope to clarify within this blog article.
So before I go any further into the factors that have us here today, let me explain to you how the appraisal trainee process works, and I will use my State of Georgia as an example since I know the requirements. I will say that most states have similar conditions; however, some criteria may be slightly different.
Below are the requirements to become a State Licensed Appraiser Trainee in GA as per the GA appraisal board.
- Must be at least 18 years of age.
- Must be a high school graduate or the holder of a certificate of equivalency.
- Must have successfully completed 90 hours of qualifying courses approved by the Board:
- 30 hours of Basic Appraisal Principals
- 30 hours of Basic Appraisal Procedures
- 15 hours of Uniform Standards of Professional Appraisal Practice (USPAP)
- 15 hours of Residential Report Writing and Case Studies
- All applicants for the State Trainee classification must have also completed an AQB approved Supervisory/Trainee Course. Applicants for the State Registered classification are not required to complete the Supervisory/Trainee Course to obtain the classification; however, they will need to have completed the course prior to completing any supervised assignments that will be used to meet the experience requirements for obtaining a higher classification level.
- Submit the appropriate application and fee to GREAB.
- A copy of the applicant’s criminal history or Georgia Crime Information Center (GCIC) Report must accompany the application. If the report indicates any criminal conviction, additional documentation may be required. See the application for details.
Now that you have completed the above, there is an additional requirement. This requirement is to gain your experience hours by working under a Supervisor or Mentor. Experience hours consist of fieldwork, filling out reports, and researching and analyzing the markets. Georgia requires 2000 hours of mentor/supervisor training hours in 12 months, but also 25% of experience hours must be in complex one to four-unit properties.
Here is something else that’s being overlooked by many. Real Estate Appraising consists of many diverse scenarios and factors. Each appraisal assignment is unique and requires the Appraiser to utilize their knowledge and skillset to analyze the data to complete a credible report correctly. It’s not as easy as just going online to Zillow (The A in Zillow stands for Accuracy) or any of the other online platforms. Why is that? Algorithms do not consider the condition of the home’s interior ( was it remodeled, outdated, filthy floors by pets, non-permitted spaces) or the external factors (power lines, easements, busy roadways, etc.). These are just some reasons that an actual human appraiser should visit your home to gather the correct data to present your home value more accurately.
First, let’s discuss the issues and narrative. Then, I’ll explain why and add my comments to it.
- Reasons/Factors as to why there is this narrative and the issue we have today.
- Appraisal Management Companies. In 2009 overnight, Appraisers from across the country were stripped of every client they worked hard to obtain, maintain and have a relationship with. The reason was implementing the now-defunct HVCC (Home Valuation Code of Conduct Law) created by then-Attorney General of NY and now disgraced Governor Andrew Cuomo. AMCs have been around before HVCC; however, this law made it so that there would be a third party in-between the Appraiser and lender. Appraisers could no longer solicit work from lenders or mortgage brokers. The role of the AMC was to manage the appraisal process, locate and assign appraisal orders. Now, this is where it gets messed up. The law never stated how an AMC would be compensated. AMCs, therefore, would take a portion of the Appraiser’s fee to pay themselves. Overnight appraisers charging $500 for an appraisal were now subjected to offers from the AMCs to perform jobs at half that fee and sometimes even less. As time went on, Fees started to rise; however, to this day, the AMCs still broadcasts orders out to many appraisers to find the cheapest and fastest appraiser instead of the one that has the most experience. Think about it, how can an appraiser take on a trainee and make it financially feasible for their business to succeed at such low fees and the mercy of the AMCs?
- Many lenders and their AMCs do NOT allow Trainees to inspect properties on their own. See, most lenders want the Mentor/Supervisor to accompany the trainee to every job and guide them along the way. As I will discuss later, Fannie Mae does not prohibit trainees from inspecting alone as long as the Supervising Appraiser follows the rules I’ll outline later. To go even further, each State has its requirements for trainees and inspections. This complicates things even more. So we have individual states that also set their requirements combined with lenders that set their own. Why does this have to be so hard? Please see this link below to see how each state handles this.
I will say that having the mentor accompany the trainee to inspections is very important in the first few months of jobs. But why can’t an adequately trained trainee after time be able to conduct an on-site inspection on their own once they have shown the ability and competency to do so? This would allow the Mentor/Supervisor to perform additional appraisal assignments and get more work done for their clients. Now think about this, and I know my answer. Suppose an Appraiser is allowed to train a trainee to the point of being competent and can utilize them to inspect properties to gather the correct information. Wouldn’t that make it more enticing for current appraisers to take on a trainee to expand their business and make more money?
What if these AMCs that take a portion of the fee were to be paid per order by the lender they represent directly instead of taking a portion of the appraisers fee? What if we allowed appraisers to operate like anyone else with a business and not be bound to regulations like TILLA or RESPA? Appraisers for the most part are independent, however it’s amazing how Lenders and AMCs are able to quote appraisal fees from a sheet of paper based off AMC fee studies. So with that you see these AMCs creating staff appraiser positions so that they can not only make more money, but control the process.
3) Not Enough people want to get into the profession.
This one makes me laugh. Why? Well, I run a group of over 2.6K aspiring men and women who are either trainees or want to be trainee appraisers. I created this group to help others who want to get into this profession or are already a trainee to find a mentor and learn from other experienced appraisers. So the narrative that it’s too hard or there is just no interest in the profession is nonsense See below
If these many people are looking to become appraisers, why are they having such a hard time? Go back to the first reason and my first two answers, and you might have a better idea.
Now that we explained everything, The solution seems very simple, right? Let’s fix this AMC model or get rid of it, and let us get lenders to allow trainees to inspect on their own when ready. Seems pretty logical based on what I have stated. Not So Fast.
Here are the solutions The Appraisal Foundation, The FHFA, and AMCs have come up with as they continue to push the false narrative in their favor
1) Desktop/Hybrid Appraisals: I discussed this in my last blog, so I won’t go further into it other than, let’s just let anyone out there (Agent, Homeowner, Uber Driver, Delta Employee etc.) be able to inspect a home and gather data while not being properly trained, licensed, have liability, or be bound by laws and regulations INSTEAD of an adequately trained trainee.
2) PAREA (Practical Applications of Real Estate Appraisal) PAREA is an alternative pathway for aspiring appraisers to gain their experience hours to become licensed or certified appraisers. Here is the breakdown of PAREA as per the Appraisal Foundation.
- It provides an alternative to the traditional supervisor/trainee model.
- Participants complete all Qualifying Education prior to beginning program.
- Initially available for Licensed Residential and Certified Residential experience credits. Partial experience credit for the Certified General credential can also be awarded.
- When complete the participant is eligible for up to 100% of experience credit for Licensed and Certified Residential credentials.
- Providers and participants must complete training on all topics listed in the detailed content outline.
- Participants will receive periodic mentoring throughout, ensuring sufficient demonstration of experience and understanding prior to moving forward in the program.
- Participants will be required to produce USPAP-compliant appraisals within the program.
- Participants, successfully completing PAREA must also pass the national licensing and certification exam for the appropriate credential level.
So basically, they will now allow anyone to tackle their Experience hours online and demonstrate that to another person online. It’s called EXPERIENCE HOURS for a reason To gain experience in the field in your market to learn, understand, and demonstrate competency. I mean, I’m sure you all are perfectly fine with a mechanic that has never touched a car before performing work on yours because they took classes online or having an electrician come to re-wire your home with no on-site training at all. Hell, why not have an esthetician perform an acid peel on your face without having any proper Experience training. ( I am married to one, and I will say that I would never allow anyone untrained to do it)
So what’s the solution, you ask? It’s straightforward, and I will outline them below:
1) Allow Trainees to inspect properties on their own when the mentor deems they are ready. If trainees must pass some exam or on-site demonstration to show they have gained the proper experience and knowledge to go out and perform inspections, so be it. This will help get more appraisals done by freeing up the supervisor. It would also allow more appraisal assignments by professionals who have the knowledge and experience to do so.
2) Get lenders on the same page as Fannie Mae and allow trainees to inspect properties or be used more adequately. For example, why does Fannie Mae enable trainees to perform inspections without a supervisor present, but many lenders do not? The following is straight out of the Fannie Mae selling guide regarding trainees:
Fannie Mae allows an unlicensed or uncertified appraiser or trainee (or other similar classification) to perform a significant amount of the appraisal (or the entire appraisal if they are qualified to do so). If an unlicensed or uncertified individual provides significant professional assistance, they must sign the left side of the appraiser certification as the Appraiser if
- they are working under the supervision of a state-licensed or state-certified Appraiser as an employee or sub-contractor,
- the right side of the appraiser certification is signed by that supervisory Appraiser, and
- it is acceptable under state law.
If the jurisdiction does not provide license numbers for trainees, the term “Trainee” should be entered in the “Other” field in the Appraiser Certification section.
To further this Fannie Mae sets forth criteria for supervisors:
As noted in the License and Certification section in this topic, Fannie Mae allows an unlicensed or uncertified appraiser, or trainee (or other similar classification) that works as an employee or subcontractor of a licensed or certified appraiser, to perform a significant amount of the appraisal (or the entire appraisal if he or she is qualified to do so), as long as the appraisal report is signed by a licensed or certified supervisory or review appraiser and is acceptable under state law.
If a supervisory appraiser is used, the supervisory Appraiser does not need to physically inspect the subject property or comparables, but must sign the right side of the report and certify that they
- directly supervised the Appraiser that prepared the appraisal report,
- have reviewed the appraisal report,
- agree with the statements and conclusions of the Appraiser,
- agree to be bound by certifications as set forth in Fannie Mae’s appraisal report forms, and
- take full responsibility for the appraisal report.
In closing, the appraisal profession is going through many changes and challenges. With each challenge or issue, the powers at large take it upon themselves to try and fix things while neglecting to speak with actual appraisers. While they try to fix things, they create more issues that require more fixing. Suppose they would have spent as much time trying to make things easier for trainees and supervisors as they have to create new forms, new laws, new appraisal products, and trying to satisfy their shareholders, etc. In that case, most of the issues we face today may not have come about. Instead of focusing on the real problems such as AMCs, low fees, lender issues, and getting more people into the profession to replace those that left due to the changes in 2009, they choose to and continue to make a mess of this profession and create more issues
While this is one of my opinions of a solution, I do think there can be very many more that could help this profession progress in the right direction if they address the right issues and stop creating more