Affidavits not sufficient for CE or Certification experience and education: ASC

Beginning January 1, your state may hold up a stop sign if you try to apply for certification with an affidavit, and may audit you to ensure your CE affidavit is true.

The Appraisal Subcommittee (ASC) announced last month and notified all states that states cannot accept experience-related affidavits from applicants for certification (that is, Certified Residential or Certified General classifications), nor for qualifying education for initial certification without verifying that the applicant’s claimed education courses are acceptable under AQB Criteria, and that the applicant has successfully completed the courses.  A state must require experience documentation to support the appraiser’s qualification for the certified classification, not just the incremental amount of experience required to move from the non-certified to the Certified classification.

For example, if a state accepts an experience affidavit from an appraiser to support the appraiser’s initial hours to qualify for the Licensed classification, and subsequently, the same appraiser applies to upgrade to the Certified Residential classification, the state must require documentation to support the full experience hours required for the Certified Residential classification, not just the difference in hours between the two classifications.

For Continuing Education, states are now required to establish a means of validating affidavits submitted to show CE has been obtained in the aggregate.  In other words, it may be the case (depending on your state’s response to the ASC policy change) that you may continue to submit affidavits for CE credit.  But the ASC will require the state to audit post-approval a statistically relevant number of affidavits to ensure the affidavits are true, that is, that you took the course as you stated in your affidavit.

If you’re audited, the audit will be completed within 60 days from the date your renewed credential is issued.  The state will determine through independent investigation that you successfully completed the course(s) you say you did.  According to the ASC, “When a State determines that a certified appraiser does not meet the AQB’s minimum continuing education criteria, the State must take appropriate action in the most expeditious manner to suspend the appraiser’s eligibility to perform appraisals in Federally related transactions.” The state must also notify the ASC so that it can update your record in the National Registry.

The ASC said that state audits showed that from state to state affidavits were found to be false from 18 to 66 percent of the time, and that some states did not take disciplinary action against applicants who falsified government documents.  And in all cases, appraisers who submitted false affidavits were allowed to continue appraising in Federally related transactions.  In a letter dated August 25 to all states, the ASC announced its affidavit policy change and required compliance by January 1.

a la mode offers training that is certified for Continuing Education in a number of states.  Certificates are always provided promptly, either at the completion of the course or by mail afterward, so for our CE, you shouldn’t have to rely on just an affidavit.  But in the event a state were to contact us about your attendance at one of the courses we run, our database records will make verifying your attendance a nearly immediate thing.  We won’t be a roadblock for you if your CE is audited, we can promise you!