The college requirement standing between a Texas home appraiser and the state’s two highest credentials could disappear within weeks, and nobody in Texas gets a vote on it.
The Texas Appraiser Licensing and Certification Board was briefed Nov. 6 on the third draft of a national rewrite that would scrap the college-education requirement for the two certified appraiser credentials — the ones that let someone value a house of any price, or a commercial building. The same draft would let an entry-level candidate satisfy all 1,000 hours of supervised work Texas demands by writing sample reports and defending them orally instead.
Texas gets no say because it never claimed one. State law makes an applicant complete “the number and type of classroom hours or other educational qualifications required by the Appraiser Qualifications Board,” and sets the experience minimum the same way (§1103.202) — that board being a panel of the congressionally authorized Appraisal Foundation. The board’s own rules repeat the delegation and name no edition or date (§153.13, §153.15). When the national criteria move, the Texas requirement moves with them, without a Texas rulemaking, comment period or vote. As The Texas Dispatch reported in August, two Appraisal Foundation trustees came to Austin and commended the board for exactly that arrangement.
For anyone trying to get into the business, the rewrite is relief. Texas asks a certified residential applicant for 200 hours of coursework, 1,500 supervised hours over at least a year, and one of six college options — among them a bachelor’s degree in any subject, 30 semester hours of named courses, or five clean years holding the entry-level license. That last one already lets a working appraiser skip college. The draft would delete the block.
For the people on the other end of an appraisal — a buyer, a lender, a homeowner arguing about a number — the trade is harder to price. The board’s general counsel, Kathleen Santos, did not dress it up:
“A lot of this is lowering the standard and we as states have the ability to go above it”
Going above it would take changes to Texas statute, she said, and she expected to seek some in the session opening in January. Asked whether the board could simply put the degree back, she said there is “a mechanism to add that back in.” Then she named the catch. Texas honors other states’ licenses, so “someone goes to another state to become licensed there and they’re licensed they can still get licensed reciprocally here.” A member saw it at once — “if you have reciprocity and their qualifications are vastly different than our expectations then that could be a problem.”
And the pressure runs one way. A board member recalled a presentation to the board a meeting or two ago at which the national board was “actively encouraging states to drop any additional qualifications.”
The case for the rewrite is scarcity: the profession is old, shrinking and hard to enter without a relative in it. The National Association of Realtors, in an Oct. 20 letter, called the degree change and the rest “positive changes that appropriately focus attention on whether an applicant has demonstrated the competencies required for a credential”. It drew one line, over a piece Texas’s own education committee has already written off. The draft would make recurring fair housing and valuation bias training optional, and the Realtors said no: “Fair housing competency is not established solely at the point of entry into the profession.”
Reporting its October meeting, committee chair Rolando Castro said the valuation bias and fair housing course “is probably no longer going to be a required course” for appraisers keeping a credential current, and that the committee had stopped gathering appraisers’ feedback on it.
No Texas appraiser group, lender or consumer organization has taken a public position on this draft; a search came back empty. Among regulators elsewhere the mood was not warm. A member who attended the sessions at a national regulators’ conference in late September reported it bluntly:
“We didn’t hear any strong approval. We did hear a lot of silence.”
Comment closed Oct. 25. The national board’s fall public meeting is Nov. 19, a one-hour virtual session for which no agenda has been published; Santos told the board it could adopt the criteria there. Chair R. Chance Bolton told the room to write anyway: “well I would encourage all stakeholders to make your voice heard one one way or the other.” If the draft is adopted as written, it takes effect July 1, 2027, and states have until Jan. 1, 2029 to conform. The Texas board meets again Feb. 19 — by which time the Legislature will be sitting and Bolton’s term, like the vice chair’s, will have ended in January.
Appraisal-firm rules, adopted without a word of comment. The board adopted amendments to its chapter governing appraisal management companies — the middlemen who keep panels of appraisers and hand out mortgage assignments — including language making explicit that it may discipline the person who controls a firm, not only the firm, plus a catch-all ground for conduct warranting revocation. Staff said no comments were received. The vote was unanimous and took about two minutes; the Dispatch’s preview had expected this to be the morning’s story. Two seats empty. The chair said the board sat seven of nine, after the resignations of Stephanie Robinson, who took a federal job, and Clayton Ripley, whom Gov. Greg Abbott appointed to the Teacher Retirement System board. Executive Director Chelsea Buchholtz said the incoming Hinojosa administration’s appointments office would fill them, and expected that to take time. Complaints up, licensees down. Buchholtz reported license holders down about 3.6% year over year alongside a significant rise in applications, and a 26% jump in complaints, most from consumers. It also cleared a federal audit with its highest rating and won $239,000 in grants.