On October 28, 2016, NAR submitted a comment letter to the Appraiser Qualifications Board (AQB) in response to their second exposure draft concerning proposed changes to the AQB’s Real Property Appraiser Qualification Criteria. NAR agreed with the AQB’s proposed reductions in degree requirements for Licensed and Certified Residential appraisers and asked that prior work experience count toward the degree requirement for Certified General appraisers. While NAR agreed with the AQB’s proposed removal of time limits on obtaining experience hours, NAR is concerned that reducing the hours requirement for all appraiser classifications could weaken the quality of new appraisers entering the field.
In the letter, NAR wrote, “While NAR is supportive of the AQB’s proposed removal of time restraints on completing the experience requirements, our appraiser members have expressed concern with the reduction of required experience hours for each classification. Supervisory Appraisers agree that the most useful preparation for becoming an appraiser is the actual performance of an appraisal. There is no substitute for experience and by reducing the experience hours necessary for certification, the AQB would be jeopardizing the quality of incoming appraisers into the profession.”