I am cautiously supportive of the AQB exposure draft.
But let’s not pretend every part of it is ready for prime time.
“Trainee appraiser” and “associate appraiser” are basically the same thing.
The industry just cannot agree on what to call them.
Either way, the concept is simple:
They work under a supervising appraiser.
They practice within that supervisor’s scope.
They are trained, reviewed, corrected, and tied to a licensed or certified appraiser who has liability on the line.
That is not reckless.
That is how professionals are built.
Here is what makes no sense.
The industry gets nervous about supervised trainees…
But seems increasingly comfortable with waivers, alternative products, AI-assisted processes, and property data collected by people appraisers do not know, did not train, did not supervise, and may know almost nothing about.
Yet we are supposed to rely on that data to produce a credible report?
But the supervised trainee is the scary part?
Come on.
If a property data collector is acceptable, then a supervised trainee appraiser should not be treated like a liability bomb.
The trainee is connected to the valuation process.
The trainee is learning from an appraiser.
The trainee is being reviewed by an appraiser.
That matters.
Those are not equal risk profiles.
Now, my concern:
Licensure based on only three sample appraisals is a low bar.
Really low.
Three samples is not a meaningful demonstration of competency.
It is a snapshot.
If FHA or other major lending channels eventually recognize that license level, the standard needs to mean something.
Otherwise, we are not fixing the pipeline.
We are watering down the credential.
I do not think we have a true appraiser shortage today.
But I do think we have a pipeline problem.
And UAD 3.6 may push us toward a real shortage if we do not get serious.
I get approached by people all the time who want to become appraisers.
Then I explain the actual path:
Education.
Finding a supervisor.
Limited assignment eligibility.
Client and investor restrictions.
And the reality that it may take around five years before the money really starts to make sense.
Their face usually changes.
The interest is there.
We lose them when they see the road.
Many appraisers would train if the system made it practical.
But when lenders, investors, AMCs, and risk policies make trainee involvement difficult, limited, or risky for the supervisor’s business, we should not act shocked when the pipeline is thin.
That is not a mystery.
That is the market responding to the rules placed around it.
Better pathways are needed.
Fake standards are not.
Protecting the profession matters.
Choking off the future of it is a mistake.
Both things can be true.
If you care about the future of valuation, comment on the exposure draft.
Put it in writing.
Be the squeaky wheel.
Because if appraisers stay quiet, other people will keep designing the future of this profession for us.
#appraisal #realestateappraisal #appraiser #valuation #AQB #traineeappraiser #UAD36
Hardesty Appraisals 