Appraiser License Defense
Representation Before the Board
The State Board of Certified Real Estate Appraisers certifies residential, general and broker appraisers, licenses appraiser trainees, certifies Pennsylvania evaluators and registers appraisal management companies. The Board applies the Uniform Standards of Professional Appraisal Practice (USPAP) in deciding whether an appraisal was properly developed and reported.
Complaints frequently come from lenders, borrowers, review appraisers and appraisal management companies, and they often allege that an appraisal departed from USPAP, relied on inappropriate comparable sales or reached a value that could not be supported. Because the Board reviews the appraiser's workfile, the completeness of the workfile is often as important as the report itself.
Mimm Law, LLC represents appraisers, trainees, supervisors and appraisal management companies at every stage of a Board matter, from the initial inquiry through final order.
Governing Law
- Board
- State Board of Certified Real Estate Appraisers
- Statute
- Real Estate Appraisers Certification Act, 63 P.S. § 457.1 et seq.; Appraisal Management Company Registration Act, 63 P.S. § 457.21 et seq.; Assessors Certification Act, Act of April 16, 1992, P.L. 155, No. 28 (certified Pennsylvania evaluators)
- Regulations
- 49 Pa. Code Chapter 36
- Licensees
- Appraisers and appraisal management companies
- Renewal
- Biennial; credentials expire June 30 of odd-numbered years
Who the Board Regulates
- Certified residential appraiser
- Certified general appraiser
- Broker/appraiser certificate (a closed class; no new certificates have been issued since 1998)
- Licensed appraiser trainee
- Certified Pennsylvania evaluator
- Appraisal management company registration
Grounds for Discipline
Section 11 of the Real Estate Appraisers Certification Act (63 P.S. § 457.11) authorizes the Board to discipline a certificate or license holder for, among other things:
- Obtaining a credential through a false statement or by withholding information
- Failure to meet the minimum qualifications for the credential
- A conviction substantially related to the duties of an appraiser
- Dishonesty, fraud or misrepresentation intended to benefit the appraiser or harm another
- Violation of the appraisal standards adopted under federal law, including USPAP
- Failure to use reasonable diligence in developing an appraisal
- Negligence or incompetence in developing an appraisal or preparing a report
- Accepting an assignment contingent on reporting a predetermined result, or a fee contingent on the value reached
- Breach of confidentiality
- Discipline in another jurisdiction, or loss of the right to practice before a federal or state agency
- A civil judgment finding that the appraiser prepared a fraudulent appraisal
Sanctions the Board May Impose
The Board may deny a credential, issue a public reprimand, revoke, suspend, limit or restrict a credential, place a licensee on probation, or restore a credential subject to conditions. A revoked certificate or license cannot be reinstated unless the Commonwealth Court orders it; after at least five years the person may reapply but must meet all qualifications, including the examination. The Act authorizes civil penalties of up to $10,000. Appraisal management companies are subject to discipline and civil penalties under the Appraisal Management Company Registration Act.
In addition to the sanctions in the Board's own statute, Chapter 31 of Title 63 of the Pennsylvania Consolidated Statutes authorizes each licensing board to impose a civil penalty of up to $10,000 per violation and to assess the costs of investigation against a licensee found to have violated the law.
Obligations That Often Lead to Board Matters
USPAP Compliance
Every appraisal must comply with USPAP, including its recordkeeping, competency and scope of work rules. A workfile that does not support the report is a frequent source of charges.
Trainee Supervision
A trainee must work under a certified residential or general appraiser who has at least five years of experience, has been certified and in good standing in Pennsylvania for the three years before notifying the Board, has had no disqualifying discipline in those three years, and has completed the supervisory course; a supervisor may supervise no more than three trainees at one time. The supervisor must directly supervise and control the trainee's work and assumes total responsibility for the contents of the appraisal report, including all value conclusions. A trainee license may not be renewed more than four times unless the Board allows it for good cause.
Continuing Education and Reporting
Appraisers must complete the continuing education required by the AQB Qualification Criteria each biennial period, including at least 2 hours on the Act, the regulations and Board policies. Beginning with the 2025-2027 renewal, appraisers and trainees must also complete an AQB-compliant course on valuation bias and fair housing laws and regulations: 7 hours the first time and at least 4 hours at each later renewal. Discipline elsewhere and criminal convictions must be reported to the Board within 30 days.
Matters We Handle
- Allegations of departure from USPAP
- Complaints from lenders, borrowers and review appraisers
- Workfile and recordkeeping deficiencies
- Supervision of trainee appraisers
- Continuing education audits
- Criminal charges and convictions affecting licensure
How We Can Help
Board Investigations
Upon receipt of a letter of inquiry, a subpoena or contact from an investigator, the firm evaluates the allegations, reviews the licensee's records, prepares a written response and attends any investigative interview. In some matters, an early, well-documented response may resolve the matter before formal charges are filed.
Formal Charges and Hearings
When the Commonwealth files an Order to Show Cause, the time to respond is short, and a respondent who misses the deadline may be held in default and the facts alleged deemed admitted. The firm prepares and files the answer, negotiates a consent agreement where one serves the client's interests, and tries the matter before the hearing examiner or the Board where it does not.
Applications and Reinstatement
For applicants whose history may raise questions, and for licensees seeking reinstatement after suspension, revocation or lapse, the firm assembles the application and supporting record and presents the matter to the Board.
Questions Licensees Ask
A review appraiser disagrees with my value. Is that a violation?
Not necessarily. A difference of opinion as to value is not, by itself, a USPAP violation. The question before the Board is whether the appraisal was developed and reported in accordance with USPAP and with reasonable diligence. A careful response that walks through the scope of work, the data relied upon and the reasoning is often effective.
What will the investigator ask for?
The investigator will ordinarily request the complete workfile, the engagement letter and any communications with the client or lender. The workfile should be preserved exactly as it existed; documents should not be added or altered after a complaint is received.
Can I be disciplined for a trainee's report?
Yes. A supervising appraiser assumes total responsibility for the contents of the report, including all value conclusions, and may face discipline for the trainee's errors or for failing to supervise as the regulations require.
Should I speak with an investigator before I have counsel?
A licensee who receives a letter of inquiry, a subpoena or a telephone call from an investigator with the Bureau of Enforcement and Investigation should be courteous and should note the investigator's name and contact information, but should not give a substantive statement before obtaining advice. Anything said to an investigator may be included in the report reviewed by the prosecuting attorney and, later, by the Board. Counsel can determine what is being alleged, gather the relevant records and prepare a response that is accurate, complete and appropriately limited.
Must I report a criminal conviction, plea or ARD, or discipline in another state?
Yes. Pennsylvania law requires every licensee to notify the licensing board in writing within 30 days of discipline imposed by a licensing authority in another jurisdiction and of a finding of guilt, guilty plea, plea of nolo contendere, probation without verdict, disposition in lieu of trial or Accelerated Rehabilitative Disposition on a felony or misdemeanor charge. Some boards' regulations impose additional or earlier reporting duties, including, for nurses and massage therapists, a duty to report the filing of criminal charges within 30 days. A failure to report is itself a ground for discipline, and it is frequently charged alongside the underlying conduct.
Meet Your Attorney
Steven A. Mimm, Esq.
Founder, Mimm Law, LLC. Admitted in Pennsylvania (2008) and New Jersey (2022).
From 2014 to 2022, Attorney Steven A. Mimm served as a prosecuting attorney bringing disciplinary actions on behalf of the Bureau of Professional and Occupational Affairs before Pennsylvania's licensing boards. That experience informs how the firm evaluates evidence, negotiates with the Commonwealth and prepares cases for hearing. Where a licensee also faces criminal charges, the firm handles the licensing matter and coordinates with the licensee's criminal defense counsel.
Related: All Licensing Boards · Licensing and FAQs
Last reviewed September 2026. The information on this page is general in nature and is not legal advice. Contacting the firm does not create an attorney-client relationship.