Q. What happens to an application for licensure once it reaches the Board office?
A: All mail is opened in a central location and distributed to the appropriate staff person. The assigned Technical Records Specialist processes the application and sends a letter to the applicant requesting any missing items to complete the application. Once the requested items are received, a letter is sent to the applicant requesting 2 specific work samples chosen from their log.
Q: How often does the Idaho Real Estate Appraiser Board meet?
A: Regular Board Meetings are typically held every other month. Refer to the Calendar of Events link for the next scheduled Board Meeting.
Q: When may I expect a response regarding my application?
A: Within 2-5 business days after the Board meeting, you will receive written communication regarding the Board’s review.
Q: How many hours of continuing education are required to renew my license?
A: Each licensee is required to obtain thirty (30) classroom hours of continuing education every 24 months prior to license renewal. This includes the requirement to attend an approved seven (7) hour USPAP update course once every two (2) years. The 7-hour USPAP update course will count towards the 30 hour requirement.
Q: Do I submit my continuing education hours to the Board office?
A: No, certificates of completion are only required to be submitted if a licensee has been randomly selected for a continuing education audit, or to reinstate an expired license. It is the licensee’s responsibility to maintain documentary evidence of compliance with the CE requirements. The Board will conduct random audits to ensure compliance with the CE requirements.
Q: Can I take the 30 hours of continuing education online?
A: Yes, you may take all of the required 30 hours of continuing education online, including the 7-hour USPAP Update course.
Q: Does a registered trainee have to have signed the original report for it to be considered for experience credit? What if the client will not allow a registered trainee to sign the report?
A: Per USPAP, the report must include an acknowledgement of the appraisal assistance. As noted below, the name of each party must be stated in the certification AND the extent of that assistance must be detailed in the report, whether it is in the certification or elsewhere.
Standards Rule 2.3:
The names of individuals providing significant real property appraisal assistance who do not sign a certification must be stated in the certification. It is not required that the description of their assistance be contained in the certification, but disclosure of their assistance is required in accordance with Standards Rule 2-2(a) or (b)(vii), as applicable.
Standards Rule 2.2 (a or b (vii))
When any portion of the work involves significant real property appraisal assistance, the appraiser must state the extent of that assistance. The signing appraiser must also state the name(s) of those providing the significant real property appraisal assistance in the certification, in accordance with Standards Rule 2-3.45
If this was not done in the original report, the applicant should include a statement detailing the level of appraiser assistance with the work product submission and it must be signed by the signing appraiser and the trainee.
Q: Can a registered trainee have more than one supervisor?
A: There is no limit to how many supervisors each registered trainee can have, however, each appraiser who provides a trainee with supervision during the trainee period must complete a Supervising Appraiser Affidavit. This form must be completed and approved prior to obtaining experience hours. Experience hours that are gained prior to or without approval of the Supervising Appraiser Affidavit will not meet the licensure requirements of Idaho.
Q: I am applying to licensure in another state and certification of my license in Idaho is required. What is the process?
A: Each state requires different forms of certification of licensure. Please check with the state where you are applying to see what is required before requesting certification from Idaho.
Certifications can be obtained two ways from Idaho:
Free primary source verification of license/registration status may be obtained via the web at https://dopl.idaho.govClick on search licenses and registration. These certifications contain all public information.
If the receiving state doesn’t accept web-based certifications or requires information exempt from third-party disclosure (example: exam scores) to be included in the certification, use this form, which must include a notarized signature of the license holder and a $10.00 fee.
Q: What if there are errors in the original report that I want to correct?
A: You may correct them, but DO NOT alter the original report. Submit the corrections separate from the original report (original report must be signed); or include the original report in its unaltered format and include a second copy that incorporates the changes (both reports must be signed).
Q: What do I do if the results of the cost and income approaches support changes to the sales comparison approach or the indicated market value or I find errors in the original report that I want to correct?
A: This is not unusual since you now have more data to consider. The purpose of the submission is to show the board that you understand and are in compliance in USPAP, including the performance of all three approaches to value, how they are interrelated, and how to reconcile the results. Therefore, if completion of the other approaches to value supports changes in the adjustments made on the sales comparison grid or supports a different indicated value, then these changes not only should, but must, be made. Think of it as a “revised” report. The submission will not be accepted if the applicant does not recognize and make these changes. DO NOT alter the original report but submit it separate from the corrected documents (original report must be signed); or include the original report in its unaltered format but include a second copy that incorporates the changes (both reports must be signed).
Q: What if one of the reports that the board has requested is a new construction making it impossible to adjust for accrued physical depreciation in the cost approach?
A: Contact the Board office immediately and another work product will be requested. If the Board determines that the work products submitted do not include all three approaches to value and include an analysis of the subject’s accrued depreciation, they will not be reviewed for compliance and revised, or new reports will be requested. The board reviews are only done during scheduled board meetings.
Q: What if I cannot find enough data to complete all three approaches to value?
A: Contact the Board office immediately and another work product will be requested. If the Board determines that the work products submitted do not include all three approaches to value and include an analysis of the subject’s accrued depreciation, they will not be reviewed for compliance and revised, or new reports will be requested. The board reviews are only done during scheduled board meetings.
Q: Am I violating USPAP by changing the original report?
A: No, USPAP allows an appraiser to revise a report for either corrections or additions. The Board is required to acknowledge USPAP violations by the signing appraiser or someone providing significant appraisal assistance.
Q: What are the most common reasons for the Board to request additional information or corrections?
A: The submission did not include a copy of the original, unaltered, and signed report separate from any corrections or changes. The submission did not include all three approaches to value, whether in the original report, or in appended information. The Board will not review a report that does not contain all three approaches to value.
Sales concessions were not adjusted for correctly.
Distressed sales, short sales, and REOs were included in the analysis but were not handled correctly, i.e., if the sales are considered to be representative of “market value”, a clear explanation should be included in the report detailing this; if the sales are not considered to be representative of “market value”, they should not be included or they should be adjusted and a clear explanation should be included in the report on why they were included and how they were adjusted.
The value being requested by the client is a “distressed” value and/or with a shorter than typical marketing period, resulting in a discounted value conclusion and the report is prepared on the wrong form with an incorrect definition of the derived value (i.e., the preprinted information on the Fannie Mae 1004 form states that the value is “market value” and the definition is included). The report must clearly state the type of value being derived and a definition of that value.
The report was prepared for someone other than a lender and/or for some other reason than determining market value but was prepared on the Fannie Mae 1004 form which is solely for use in mortgage lending for federally regulated transactions and for market value estimates.
The submission did not include all the “major” items noted on the board’s checklist. Items missed most frequently include:
Lack of at least two sets of paired sales to support major adjustments on the sales comparison grid.
The paired sales data is analyzed and applied incorrectly. It is not required that the paired sales used to support the adjustments be the same sales used in the sales comparison in the report. The adjustments on the sales comparison grid should be extracted from the best data available that may be derived from the market and it is unlikely that they would be the same comparables as the ones used in the report.
Incorrect analysis of the data (i.e., the market is in decline and the subject property has been listed for sale for an extended period of time for $100,000 but the indicated market value is $115,000 with no explanation).
Q: There is no reconciliation of the data in each of the approaches to value; simply taking the “average” of the results is not acceptable without an explanation whether it is in the sales comparison approach or with the GRM data. If the data demonstrates that each result should be weighed equally, than that is certainly acceptable, but in most instances some of the data is more reliable and should be weighted.
A: There is no final reconciliation of the three approaches to data; boilerplate language is not acceptable. The final reconciliation should be specific to the property being valued and the results of each approach.
The report did not include an analysis and reconciliation of prior sales and/or active or expired listing information.
The submission did not include detail showing market-derived depreciation and applying the results correctly in the cost and sales comparison approach.
Whether a separate line item for accrued depreciation is necessary in the sales comparison grid or not, depreciation should reflect and be supported by market data. It should be consistent with the results of the analysis in the cost approach. The issue should be explained in the commentary of the report.
The review checklist item prompts for your reflection on the results of market extraction of accrued depreciation. Comment if adjustments in the sales comparison approach reflect significant variance from the market-derived depreciation indication, or should an individual comparable adjustment reflect an inconsistent result. Adjustments for Condition, Age, or Functional Utility are often the factors found to be inconsistent with properly developed accrued depreciation analysis. If differences are unexplained in the original report, those inconsistencies will require additional comment in an addendum before the report is considered complete as a pre-license work product example.
The commentary in the submission was primarily boilerplate and/or did not apply to the subject property.
Q: Can an appraiser applying to upgrade their license count experience gained by doing a practice appraisal for a friend, co-worker, or neighbor?
A: Yes, based on the Appraisal Foundations AQB criteria, an applicant can claim up to 50% of their actual experience by doing a practice appraisal for a friend, co-worker, or neighbor. Please note that each subject must be real property that actually exists, and each appraisal must meet all USPAP requirements.
Q: Is a real estate appraiser required to maintain a work file when completing compensation estimates for entities that are exempted under the law? What if an association that they are affiliated with requires a work file regardless of jurisdictional exemptions?
A: There are associations that require their members to adhere to USPAP at all times. Those associations may require the appraiser to have a work file for each appraisal performed even though it may not be required in certain instances by Idaho law because of a specific exception. The law does not require licensees to join such associations. Therefore, Idaho licensees are not legally subject to the association standards, although licensees may be required to comply with an association’s standards to retain certification or good standing within the association. Members of an association should contact their association regarding its specific requirements as to this matter. Additional information can be found on the Board’s website under the State Licensure Law and State Licensure Rules tabs, as well as the 2/12/2014 Board meeting minutes.
Q: Why did the Board propose removing USPAP standards 7, 8, and 9 from the rules?
A: The Idaho Real Estate Appraiser Board (the Board) recently proposed law and rule changes which are available for your review on the Board’s website under Proposed Law and Rule changes. The proposed law change clarifies that the definition of a “Real Estate Appraisal” regulated by the Board only includes “opinions of value of identified real estate” rather than including opinions on the nature, quality or utility of real property. The proposed rule changes exclude from the Board regulation USPAP standards 7, 8, 9 and 10. These standards pertain to the appraisal of personal property and businesses rather than real property. A number of licensees have commented regarding these proposals and the Board felt it should respond. A licensee specifically proposed these changes based upon his concerns that the definition of an appraisal was unclear under the law and the Real Estate Appraisal Act only pertains to appraisals of real property rather than businesses and personal property.
In proposing these changes, the Board requested guidance from the Appraisal Subcommittee (ASC), the U.S. governmental entity that oversees the Board with respect to real property appraisal for federally related transactions. The ASC responded that these standards “are outside the scope of the ASC since our authority is for real property appraisals for federally related transactions FRTs.” Since the Board licenses real estate appraisers its laws and rules should govern only the practice of real estate appraisers. The Board believes its laws and rules should be clear and limited to the appraisal of real estate.
In addition to real estate appraisers, many other occupations currently hold themselves out as business appraisers or possessing the ability to appraise personal property. These include accountants, real estate brokers, attorneys, financial advisers, financial experts, economists, car salesmen and others. These activities are not regulated by the Board and in some instances may be totally unregulated to the best of the Board’s knowledge. However, it is clear that the Real Estate Appraisers Act only pertains to the appraisal of real property and does not regulate your or other’s appraisal of personal property or a business.
The Board does not believe that these proposed changes will affect licensed real estate appraisers in Idaho in their business or in the practice of real estate appraising. Rather this change will clarify that the Board’s regulation of real estate appraisers is limited to the appraisal of real estate which would include an appraisal of real estate as a going concern.
