What is the Experience Audit Process Anyway?
The law requires TALCB to audit the work product of all applicants for an appraiser license in Texas. TALCB must verify that the experience claimed generally complies with the Uniform Standards of Professional Appraisal Practice (USPAP), the Rules (“Rules”) of the Texas Appraiser Licensing and Certification Board (TALCB), and the Texas Appraiser Licensing and Certification Act (“Act”) as of the date of the appraisal report.
In fiscal years 2016, 2017, and the first half of FY2018, we received an average of almost 12 audit requests per month. On May 1, 2018, the Appraiser Qualifications Board (AQB) decreased the number of experience hours required to qualify for certain appraiser license types. Since this change, the average number of audit requests received by TALCB has almost doubled to over 20 per month. Coupled with a recent staff vacancy, this 73.7% increase of incoming audits has resulted in longer processing times.
TALCB has filled the staff vacancy and is working on new strategies to reduce application processing times. We are always striving to improve customer service while not sacrificing the quality or the integrity of the audit process.
We want those who can demonstrate basic competency as an appraiser to succeed in becoming licensed appraisers in Texas. In about 95% of the experience audits we perform, the applicant is able to demonstrate competency and the experience credit is approved. For some applicants whose experience audit reveals only minor deficiencies, TALCB offers a contingent approval program. In these cases, TALCB staff will carefully evaluate each applicant’s work product to determine their eligibility for a contingent approval. If eligible, a contingent approval allows an applicant the opportunity to gain competency through additional education or mentorship and avoid denial of the license upgrade application.
Unfortunately, in about 5% of experience audits, the Board staff finds strong evidence of serious issues, such as gross incompetence or ethics violations, which cannot be remedied through a contingent approval. These issues put the public at risk and require TALCB to deny the application for a license.
If an application is denied, the person has the right to appeal the decision and have their case heard before an administrative law judge at the State Office of Administrative Hearing (SOAH). These appeals take time and involve costs including travel to Austin. Applicants in these situations may decide to hire an attorney to evaluate their case and assist in their appeal. Because it is time consuming, costly and impacts people’s chosen profession, TALCB staff carefully evaluates each case that may go to a hearing. As a result, TALCB has a near 100% success rate at SOAH for application denial cases. In fact, we have only lost one application denial case in the past 13 years.
We realize individuals just completing the training process are likely to make mistakes. We do not expect to find a perfect report or work file when performing an experience audit. However, we do take our job seriously and do our best to ensure only qualified individuals who have demonstrated general competence and ethics are available to provide real estate appraisal services to Texas consumers.
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