Pub. 6 2017 Issue 8

l e a d i n g a d v o c a t e f o r t h e b a n k i n g i n d u s t r y i n k a n s a s 20 O N NOVEMBER 1, 2017, The Appraisal Foundation through its Appraiser Qualifications Board (AQB) issued its Fourth Exposure Draft of Proposed Changes to the Real Property Appraiser Qualification Criteria (Qualification Criteria). In it, the AQB states that they have been examining potential areas of change to the Qualification Criteria for licensed and certified appraisers for two years. The KBA became aware that this effort was afoot last spring when the Third Exposure Draft was issued. In our comment letter to the AQB, we stressed the importance of making changes to the mentoring requirements of the current criteria. We have heard from many bankers who tell us that this requirement is the biggest barrier to individuals wanting to break into the appraiser business. Whether it is the risk of being liable for their mentee’s work, of the fear of not being able to earn the same living with the increased competition, the mentor program is failing in Kansas. In response, the Third Exposure Draft included an alternative method of gaining experience. It was called the Practical Applications of Real Estate Appraisal (PAREA) curriculum. PAREA was to consist of a series of modules which would emulate actual field experience through classroom teaching and the performance of actual and virtual appraisal assignments. In this Fourth Exposure Draft, the PAREA concept has been removed and is to be developed separately on a more extensive time frame than the rest of the proposal. Clearly, there were objections from the appraisal industry to this proposed alternative to the mentoring requirement. As we prepare to draft another comment letter here at the KBA, we are urging every member bank to do the same. There are also positive proposals in this draft, but it is clear that the shortage of appraisers is not being taken seriously. If this latest draft was two years in the making, one can only imagine at what date the PAREA concept or other alternatives to mentoring will be finalized. Doug and I recently attended a meeting of bank association executives where a member of the AQB was asked to speak. He asked for a show of hands of who believed there was an appraiser shortage – many hands went up. He seemed puzzled by this and then stated that those in attendance may be surprised to know that the appraisal industry did not share the belief that there was any shortage. The AQB needs to hear your stories of frustration in finding a qualified appraiser, delays in transactions, and the cost to bring appraisers from other areas. They also need to hear stories about individuals who have sought to be an appraiser, have met all the educational criteria, but cannot find anyone to mentor them. Please send your comments to: Mr. Joseph C. Traynor, Chair, Appraiser Qualifications Board, The Appraisal Foundation, 1155 15th Street, NW, Suite 1111, Washington, DC 20005. To read the entire Fourth Exposure Draft, please go to: https://appraisalfoundation.sharefile.com/app/#/share/view/ s7ce4c46184b47f9a Comments are due before Friday, January 12, 2018. By Kathy Taylor, KBA SVP General Counsel THE APPRAISAL FOUNDATION NEEDS TO HEAR CONCERNS ABOUT APPRAISER SHORTAGE…NOW KBA LEADERS LEDGER