Appraiser advocates urge TALCB to limit re‑audits of previously accepted experience hours

During the public‑comment period, Hansel Dobbs, who chairs the Association of Texas Appraisers' legislative committee, urged the Texas Appraiser Licensing and Certification Board to modernize its audit of experience logs for license upgrades. Dobbs said TALCB currently audits all logged hours when an appraiser seeks to upgrade credentials, including hours already used to obtain a current license. He argued that many of those files are older than USPAP retention rules and no longer exist, forcing applicants to restart experience logs or delaying career progression.

Dobbs proposed that TALCB accept hours previously approved for the applicant's current credential as presumptively valid and limit audits to the incremental hours necessary for the higher credential (for example, audit only the additional 1,000 hours when moving from licensed residential to certified residential, or only the additional 1,500 nonresidential hours for certified general). He said the change would protect the public by focusing reviews on the most risk‑sensitive, new assignment types and would encourage professional advancement, particularly in rural areas with shortages of certified appraisers.

Chair Oates thanked Dobbs and said staff would add the topic to the education committee agenda for further consideration; the board indicated it may request follow‑up clarification from Dobbs. No board action was taken at the meeting on this specific audit proposal.