On May 9, 2017, NAR submitted a comment letter to the Appraiser Qualifications Board (AQB) in response to the Third Exposure Draft concerning proposed changes to the AQB's Real Property Appraiser Qualification Criteria. NAR agreed with the AQB's removal of the degree requirement for licensed residential appraisers, the basic appraiser qualification, and to instead require completion of 150 AQB Core Curriculum credit hours. NAR also agrees with the AQB's proposed removal of the minimum time limits on obtaining experience hours for all appraiser credential levels.
NAR is concerned with the AQB proposal to reduce the experience hours for appraiser classifications and the impact that could have on the quality of incoming appraisers. In addition, NAR asked the AQB to consider a two-year rather than four-year degree requirement for certified residential appraisers, the mid-level appraiser qualification, and allow for prior work experience to count toward the degree requirements.