Proposed Qualification Criteria for Appraisers

Will TAF’s Proposed Criteria for Personal Property Appraisers Have Teeth?

(By Dave Maloney Sep 1, 2012) The Appraiser Qualifications Board (AQB) of The Appraisal Foundation (TAF) recently released a proposed new version (click here to view) of its Qualifications Criteria for Personal Property Appraisers. A colleague recently posited that: “Even though the proposed standards are voluntary, those of us belonging to an association will be impacted by the acceptance of the standards by the association.”

My reply was that I felt that the issue is more complicated than that.

I was a member of the TAFAC “criteria” committee back in 1998 when we first adopted the minimum qualification criteria for the personal property appraiser. As of this writing (September, 2012) those current criteria (click here to view) are in force and will remain so until the new criteria are adopted which might be in two or more years.

Those 1998 criteria are clearly voluntary for all appraisers, regardless of their societal affiliation. They criteria states so, to wit: “The AQB envisions that the [1998] Personal Property Appraiser Minimum Qualification Criteria will be used by major clients of personal property appraisers such as corporations and government agencies. It is important to note that this document sets out minimum criteria with which personal property appraisers may voluntarily wish to comply. The AQB does not foresee any governmental body utilizing these guidelines as part of a regulatory program.”

A few years ago I queried all societies and was surprised to learn that no society at all had or now has an established system for maintaining a registry of their members who meet the 1998 criteria. What is more, the 1998 criteria requires a comprehensive exam. Again, no society offers a comprehensive exam required for members wishing to voluntarily qualify. In short, to my knowledge, no society has systems in place to facilitate their members complying with the existing (1998) criteria. It would seem that the 1998 criteria has failed completely in its stated goal as noted above.

But the optional compliance requirement, for some, is now going to change. The criteria now being proposed are no longer voluntary for all appraisers.

The criteria now being proposed state that “sponsoring organizations” of The Appraisal Foundation and their members MUST comply with the criteria. Specifically, the proposed criteria state, “The [proposed] Criteria establishes minimum requirements for all personal property appraisers who are members of sponsoring organizations of TAF. Personal property appraisers who are not members of sponsoring organizations are encouraged, but may not be required, to follow the minimum education and experience recommendations established by the Criteria.”

The ASA and the AAA are the only TAF sponsoring organizations having members in the personal property discipline.

Whereas in the past societies could get away with not supporting the criteria, such a system will no longer be the case. By the way, I know of few, if any, appraisers who today promote themselves as having met even the older, 1998 criteria. That could be because today’s criteria are voluntary. But no more – at least no more for ASA and AAA members who, if the criteria are adopted, MUST comply with it.

Regarding education, the new criteria state: “Applicants must hold an Associate Degree or higher, from an accredited college, junior college, community college, or university. Accreditation shall be granted by the Commission on Colleges, a regional or national accreditation association, or by an accrediting agency that is recognized by the U.S. Secretary of Education.” Note that there is no alternative to this requirement. But the new criteria also state, in effect, that “currently-designated” members will not have to meet the college degree requirements, i.e., they are being grandfathered. It states, “While the new Personal Property Appraiser Qualification Criteria are not retroactive to existing credentials, personal property appraisers seeking new credentials or credentials in another area of appraisal/specialization expertise must comply with the new Criteria. Other than the revised continuing education requirements, these Criteria do not impose any additional requirements upon existing credentialed personal property appraisers.”

It appears that this grandfathering excuses personal property appraisers currently holding a societal designation from complying with the new, proposed criteria. Though the criteria does not state so, I am assuming, that existing members who have yet to earn a societal designation are NOT so excused.

In addition, note that the new criteria DOES apply if appraisers seek a new credential or if they seek a credential in a new area of specialization. It is not clear to me whether “seeking new credentials” would include renewing an existing credential every five years, i.e., “requalification”, as required by some societies, or if it would include upgrading to a superior level of designation (such as to Senior member from Accredited member; or to Accredited member from Candidate member, etc.)

So, here is my take on it:

If you are a “designated” member belonging to the ASA or the AAA (sponsoring organizations of the TAF), the new criteria will require you to comply with the older 1998 criteria but not the new, proposed criteria unless you choose to doso. But you will be required to comply with the new, proposed criteria should you seek a new credential or a credential in another area of specialization. If you are a “non-designated” member belonging to the ASA or the AAA, be prepared to meet the new, proposed criteria as soon as they are adopted. (All members of ASA and AAA must comply. This is a change. In the past, compliance was voluntary. The new criteria appear to clearly state that members of sponsoring organizations have no option other than to comply.)
Since members of sponsoring organizations such as the ASA and the AAA must comply with the either the old or the new criteria, those organizations must have systems in place to facilitate their members complying, e.g., to maintain registries of those who comply and to have systems in place to manage those who do not.
If you are a member of the ASA or the AAA and wish to get a new (renewed?) designation or a designation in a new area of specialization, you will have to comply with the entirety of the new criteria including obtaining, at a minimum, an Associates Degree.
If you are not a member of the ASA or the AAA, you should strive to meet the criteria even if not required to do so. What is more, any appraiser who meets the criteria (either the 1998 or the proposed) should proudly proclaim such on his or her letterhead, website, etc.