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Commission penalizes firm for altered certification language; $500 per post-consent occurrence and $3,000 penalty for inspecting appraiser

Tennessee Real Estate Appraisal Commission · July 20, 2026
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Summary

Following a complaint that a firm continued to include a problematic disclosure implying another appraiser 'performed' inspections after a consent order, the commission ordered per‑occurrence fines ($500 each for six post‑consent reports) and a $3,000 penalty for the inspecting appraiser named in the disclosures.

The commission reviewed a new complaint alleging that a firm continued to include a customized certification sentence implying another appraiser "performed" inspections despite an April 17 consent order requiring corrective education. The respondent’s counsel told staff the firm would remove the disputed sentence going forward, but commission members found multiple post‑consent instances in the record.

Commission legal staff and members discussed whether the altered preprinted certification improperly shifted responsibility or created confusion for consumers and lenders. The board approved a motion to impose $500 per report for each post‑consent occurrence (six reports were identified after April 17) and a separate $3,000 civil penalty for the inspecting appraiser whose name appeared in the disclosures. The commission also recommended reverting to the standard Fannie Mae certification wording rather than customized language in the preprinted certification block.