Volume 11, Issue 1 February 2019 IllinoisAppraiser

ILLINOIS DEPARTMENT OF FINANCIAL & PROFESSIONAL REGULATIONIllinoisAppraiserVolume 11, Issue 1February 2019What You Need to Know NowUpgrading Changes3Hybrid Assignments4Illinois appraisers, and those holdingIllinois licenses but reside elsewhere,need to embrace the AdministrativeRule changes (1455.160) that directlyaffect this year’s renewal.While the renewal deadline remainsSeptember 30, 2019, the CE Completion Deadline is June 30, 2019.This means that Illinois licensed appraisers need to complete 28 hours ofCE no later than June 30, 2019, in order to be compliant.What if an appraiser has completedsomething less than 28 hours and it’snow July 1?If you’re short by a 7‐hour CE offering,you’d be subject to a 100 per missed houradministrative fee. In this case, 700. Ifyou missed 14 hours, the fee would be 1,400.Would the fee be reported to the National Registry?No. It is not a public discipline.Would an appraiser short in hoursstill need to complete the CE orwould the fee cover it?Appraisers in Illinois need 28 hours nomatter what. An appraiser short 7 hourswould have until September 30, 2019 tocomplete the course or courses. Fees do noteliminate the obligation.What if an appraiser still hasn’t completed their CE by September 30,2019?The issue will be referred to prosecution forpossible enforcement action.If an appraiser still hasn’t compliedby September 30, 2019, and the issueis referred to prosecution, must theappraiser still complete the requiredCE?Absolutely. An appraiser’s CE obligationstill needs to be completed.What if an appraiser takes their CE inother states, will it count in Illinois?Over 500 appraisers live outside of Illinoisbut hold an Illinois license. In most cases,the Board approves out‐of‐state CE. How‐ever, approval by the Board must occurbefore June 30, 2019 in order to avoid theadministrative fee. The Out‐of‐State CEform must be completed in order for the CEto be considered.Licensed, Illinois education providershave until the 15th of each month toupload courses that will be bankedby the Division. If I take CE in thelast week of June, will it be uploadedin time?No. This is why the Division needs time toprocess renewals beginning on July 1,2019. Don’t wait until the last minute.(Continued on page 2)http://www.idfpr.com/DRE/ApprNewsletter.asp1

ILLINOIS DEPARTMENT OF FINANCIAL & PROFESSIONAL REGULATIONIllinoisAppraiserWhat You Need to Know Now(Continued from page 1)What if an appraiser is planning toretire and doesn’t intend to renew?There’s no law requiring that a licenseerenew. You’ll need to send a letter to li‐censing informing them of your anticipat‐ed retirement date. Again, this letter needsto arrive prior to June 30, 2019. Retire‐ment is seldom done without advancedpreparation. Plan accordingly.No. Only QE courses that are dually li‐censed as CE in Illinois can count for both.Ask your provider if the QE offering islicensed as CE in Illinois, too.How do I know how much CE hasbeen “banked” by the Division?Go to the following web address, enteryour license number and a list of every‐thing you’ve taken from licensed providersfor the current cycle will appear.https://www.idfpr.com/applications/ce lookup/Does the CE Lookup feature includecourses that I’ve taken in other states?No. While the Board typically approvesmost out‐of‐state appraisal education offer‐ings, we have no way to “bank” them inour system.Can an appraiser place their licenseon HOLD or InActive status?If I take an on-line CE offering on thelast day of June, but cannot completethe quiz portion until July 1, am I stillin compliance?That is not available.If an appraiser holds an ACTIVE license but doesn’t practice, are theystill subject to the AdministrativeRules regarding CE?Whether or not an appraiser is activelyparticipating in appraisal assignmentsdoes not relieve the obligation so long asthey are actively licensed.I’m trying to upgrade from trainee tocertified. I’ve been taking many QEclasses. Do these count toward my er.aspNo. Everything must be completed beforemidnight preceding July 1.This is not a brand new process forhandling CE. The Division did a “dryrun” of this entire process during the2017 renewal. The only difference wasthat the administrative fees were notemployed.You need to be diligent about completing all of your CE on time.2

ILLINOIS DEPARTMENT OF FINANCIAL & PROFESSIONAL REGULATIONIllinoisAppraiserUpgrading ChangesIn May of 2018, the AQB put forward araft of changes affecting experienceand formal education.TraineeResidentialGeneralNo sooner were the changes adoptedby AQB then my phone started ringingand my inbox was flooded with questions as to if or when would Illinoisadopt the same.Like any legislative change, it tooktime, but on November 26, 2018 thechanges were adopted and a new application was born shortly thereafter.For those seeking to become a Certified General Appraiser, the minimumrequired time in the field was cut from30 months to 18 months. However, the3,000 hour experience requirement remains unchanged.The most impactful changes came inthe form of additional options to theformal education requirement.The previously required Bachelor’sDegree requirement remains as Option1.The good news is that there are fiveother avenues available to achieving acertified credential.Option 2 outlines an Associates Degree.Option 3 details specific courses in a 30semester hour endeavor.Option 4 involves CLEP examinations.What changed?First, experience changed. For thosetrainees seeking to become a CertifiedResidential Appraiser, the number ofexperience hours dropped from 2,500to 1,500.The minimum required time in thefield was cut in half from 24 months to12 months.The trainee exam was eliminated in theAct as of January 1, 2019.Because the AQB requires that thethree core courses to obtain a traineelicense be no older than five-years old,the exam became tion 5 involves a combination ofOptions 3 and 4.Option 6 is the least likely avenue as itrequires having held a credential thatIllinois hasn’t had available for manyyears.Everything you need to know can befound under Administrative Rule1455.150.Will this increase the number of peopletrying to enter the profession?That remains to be seen. Illinois remains committed to removing as manybarriers as legally possible.3

ILLINOIS DEPARTMENT OF FINANCIAL & PROFESSIONAL REGULATIONIllinoisAppraiserHybrid AssignmentsJB Pritzker, GovernorJessica A. BaerActing SecretaryJessica A. BaerActing DirectorDivision of Real EstateIllinois Department ofFinancial andProfessional Regulation100 West Randolph Street9th FloorAppraisal UnitChicago, Illinois 60601Phone: 312/793-6608Appraisal BoardPeter Poulos, ChairPatricia L. McGarrGail LissnerJoel WardSara ChambersJohn McMahonMichael K. MorrisKenneth J. MrozekKatie McNallyCalvin L. HolmesBrian Weaver, CoordinatorEditor of IllinoisAppraiserMary Crocker, LicensingSusan Sigourney, Board LiaisonThe concept of a third party providingone or more functions in an appraisalassignment is nothing new.The response was dependent onwhether the third party’s informationwas complete enough and reliable.Back in the 1970s and 1980s there wereplenty of appraisers who used somebody else to do the sketch or to takethe pictures or to pull comps.Let’s unpack that.The “appraiser” put all of the piecestogether and signed the report.Then came USPAP in 1989.Licensing followed shortly thereafter.Today, there are a number of lendersand AMCs who believe that they’veinvented something no one else hasever considered.The bifurcated or hybrid appraisal process.To be clear, we’re not talking about“drive‐by” reports where nobody leavestheir vehicle to inspect the subjectproperty or pure “desktop” reportswhere nobody leaves their office to seeif the subject property even exists.What we are discussing in this articleare assignments where an unlicensedthird party reports to the licensed appraiser, the quality and/or condition ofa supposedly, fully inspected subjectproperty.On March 29, 2018, the ASB issued aQ&A regarding this topic.The question involved whether an ex‐traordinary assumption should be employed when a third party was used.It is the appraiser who must determinejust how reliable third party information is before committing to it.Not the client.When should an appraiser determine, asrequired by USPAP, that a third partyinspection was adequate or not?Before the assignment?During the assignment?After the assignment?If it’s before the assignment then theappraiser wouldn’t rely on it at all.How would an appraiser find out dur‐ing the assignment?After the assignment is the most likelytime an appraiser would discover anyinadequacy. By then, it’s too late.The third party inspection starts outand ends up as additional risk to thecredential holder.(Continued on page 5)http://www.idfpr.com/DRE/ApprNewsletter.asp4

ILLINOIS DEPARTMENT OF FINANCIAL & PROFESSIONAL REGULATIONIllinoisAppraiserHybrid Assignments(Continued from page 4)IllinoisAppraiserProvided as a service to licensedand registered Illinois appraisalprofessionals and AMCs as wellas Illinois course providers andusers of appraisals. This publication promotes a greater understanding of USPAP, the Act, andthe Administrative Rules of theState of Illinois.Articles found in this publicationmay not be reprinted or reproduced in any other media withoutspecific reference to this publication and the State of Illinois.Unless otherwise noted, any articleis the work of the author and doesnot necessarily represent theviews or opinions of the collectiveIllinois Real Estate Appraisal Administration and DisciplinaryBoard.What is it that a third party inspectorprovides?One prominent player in this spacewrites:“A trained, local inspector conducts a re‐view of the property. Photos are time/date‐stamped and geo‐coded to ensure validity.”Trained? In what? By whom?What is meant by review of the property?Another entity promotes:“.a hybrid appraisal that combines a boots‐on‐the‐ground inspection with a local,appraiser‐completed desktop valuation.”AMCs and lenders who create proprietary forms for hybrids are careful tocraft an elusive SOW that boxes in theappraiser and places the responsibilityfor selecting reliable information,squarely on the appraiser.not the“inspector”.In Illinois, here’s what an unlicensed“inspector”, trained or not, can confidently provide to an appraiser:Photographs? —Absolutely.Improvement Quality? —No.Improvement Condition? —No.Room Count? —Even appraisers can’tagree on room counts (attics, add‐ons,three‐season rooms), or whether certainrooms are bedrooms or not (pass‐throughs).Improvement Size—Appraisers can’tcome together on how to properlymeasure a structure. Are they ng to the nearest foot? Half foot? Norounding at all?In Illinois, filtered data needs to comefrom a licensed appraiser.What about hybrids and AMCs inIllinois?Registered AMCs certify to provide thefollowing:(225 ILCS 459/40)Sec. 40. Qualifications for registration.(6) a certification that the applicant willutilize Illinois licensed appraisers to pro‐vide appraisal services within the State ofIllinois;If it is clear that unlicensed inspectors areproviding filtered data to appraisers, anappraisal service, then AMCs havebreached this section of the Act and aresubject to enforcement action.In its simplest terms, third party“inspectors” can tell an appraiser whatthey see; not provide their opinion ofwhat they see.In short, we’re not telling anyone notto provide hybrid reports; we’re justspelling out the consequences.5

ILLINOIS DEPARTMENT OF FINANCIAL & PROFESSIONAL REGULATION Volume 11, Issue 1 February 2019 IllinoisAppraiser Illinois appraisers, and those holding Illinois licenses but reside elsewhere, need to embrace the Administrative Rule changes (1455.160) that directly affect this year’s renewal. While the renewal deadline remains