Voluntary Review of Appraisal Work Product for Trainees
The typical path to becoming a licensed appraiser in Texas is to first become an appraiser trainee supervised by a certified appraiser in Texas. Like an apprentice learning a skilled trade, trainees work under the direction of their supervisory appraiser while gaining experience in the appraisal profession. When those skills are mastered and the trainee is ready to apply for a license, the appraiser trainee must demonstrate competency three ways: completing required education, passing a comprehensive examination, and submitting sample appraisal reports/work files from their experience log for evaluation by TALCB staff for compliance with the Uniform Standards of Professional Appraisal Practice (“USPAP”). Until recently, the appraiser trainee had to complete all of the required experience hours and submit a license application before having their work reviewed by the TALCB. There was no opportunity before the actual experience audit to receive feedback on whether their work product generally complied with USPAP. If the reports selected during the audit did not generally comply with USPAP, the trainee’s application could be denied or at least delayed until additional remedial action was taken. This might include additional education, mentorship or completion of additional experience hours as a trainee. Board Rule 153.22, which became effective March 13, 2016, now gives trainees another route for feedback before they apply and go through the experience audit. This new opportunity helps trainees make corrections to their appraisal practice long before they submit an application and work product for audit. Armed with this information, applicants can be better prepared for the experience audit, increasing their likelihood of success.
Under Board Rule 153.22, a trainee may submit a completed appraisal report and work file of their choice for review by the Board. This may be done after completing 500 hours and 1,000 hours of appraisal experience. After submitting their work product with the required application and $75 processing fee, a member of the Board’s Peer Investigator Committee (PIC) (all of whom are AQB Certified USPAP Instructors) will review the work product for general USPAP compliance. Once that review is completed, the Board staff will then provide the trainee with a written report identifying any USPAP deficiencies found in their work product.
The appraisals submitted for review must conform to the requirements for qualifying experience and be completed during the period in which the trainee had the legal authority to perform the work. The categories of acceptable experience (described in Rule 153.15(e)) include: appraisal or appraisal analysis, mass appraisal, appraisal review, and appraisal consulting services. These rules are available on the Board’s website by clicking on the “Rules and Laws” link under the “Agency Information” tab at the top of the home page.
Please keep in mind that these voluntary reviews are for educational purposes only and do not guarantee the trainee’s work submitted at the time of application will pass the experience audit. What these voluntary reviews do provide the trainee is an opportunity to become aware of and correct potential USPAP compliance issues in advance of the experience audit.
This voluntary review of trainee work product generally will not result in a complaint against the trainee or supervisor. Exceptional situations that may result in a complaint include: (1) appraisers who make knowing or intentional misrepresentations, engage in fraud or criminal conduct; (2) appraisers who commit grossly negligent acts or omissions in their appraisal practice.
To request a review trainees should submit the required application form, the appraisal report and related work file, and $75 to the Texas Appraiser Licensing and Certification Board at P.O. Box 12188, Austin, Texas 78711-2188. The link to the “Application for Review of Trainee Work Product” form may be found on the Board’s website by clicking on the “Appraiser Trainee” link under the ”Become Licensed” tab on the home page.
The Board’s Enforcement Committee is currently considering measures that may benefit supervising appraisers and trainees by raising the current limit of three trainees a certified appraiser may supervise at any one time if the trainees participate in this voluntary review program.
Board staff encourages trainees to take advantage of this opportunity to improve their understanding of USPAP, so that they can better prepare themselves for successfully completing the experience audit once they apply for a license.