Appraisers are a bit different than the average real estate agent, as appraisers are first required to obtain a trainee license. Then, they need to obtain experience completing and logging appraisals before they become fully licensed. While they are working toward their full license, they are able to gradually take on more responsibilities.
Eventually, with enough experience, appraiser trainees can lawfully complete inspections without their supervisor. This frees up the supervising appraiser to take on more of their own work, making them more likely to agree to take on a trainee in the first place. What are the circumstances when a trainee may conduct appraisal inspections independently?
The law is not clear cut, but the Bureau of Real Estate Appraisers (BREA) clarified the answer in their Fall-Winter 2021 newsletter.
As part of the supervising appraiser’s duties, they need to personally inspect the property with the trainee until the trainee is considered competent to make unsupervised inspections. [Calif. Code of Regulations §3568(e)(1)]
Competency is loosely defined in the Uniform Standards of Professional Appraisal Practice (USPAP) as possessing sufficient knowledge and experience about the property’s:
- type;
- market;
- geographic area;
- intended use;
- regulations impacting the property; and
- required appraisal method.
When a fully licensed appraiser doesn’t possess the competency to perform an appraisal in a credible manner, they may still complete the appraisal assignment, as long as they disclose their lack of competence. But when a trainee lacks competency, they need to have their supervisor present.
Further, the person who performs the inspection needs to be identified in the engagement letter or the standardized appraisal form. For example, Fannie Mae’s standard Uniform Residential Appraisal Report (URAR) requires the appraiser to sign their name on page 6 of the form. When the trainee completes the inspection, they need to sign their name here, not the absent supervisor.
In this case, the client needs to be notified and agree to the trainee inspecting the property without the presence of their more experienced supervisor. Even then, when the scope of work or letter of engagement specifies the supervisor’s name as the appraiser, the trainee may not complete the inspection independently.
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