200 W. Madison
Chicago, IL 60606
October 19, 2022
Department of Licensing and Regulatory Affairs
Bureau of Professional Licensing– Boards and Committees Section
P.O. Box 30670
Lansing, MI 48909-8170
Attention: Departmental Specialist
Re: Administrative Rules for Real Estate Appraisers - General Rules, Rule Set
The Appraisal Institute (AI), the nation and state’s largest organization of professional real
estate appraisers, appreciates the opportunity to provide comments on “Administrative
Rules for Real Estate Appraisers - General Rules, Rule Set 2021-52 LR” that was
published in the Michigan Register on October 15, 2022. The AI is strongly supportive of
the rules as published, including the addition of the Practical Applications of Real Estate
Appraisal (PAREA) as an experience option and the adoption of the changes to the Real
Property Appraiser Qualification Criteria (RPAQC) related to distance education.
Practical Applications of Real Estate Appraisal
The Appraisal Institute supports and appreciates the incorporation of PAREA as an
alternative path to obtain all of the appraisal experience necessary to obtain the State
Licensed and Certified Residential Appraiser licenses, as well as part of the appraisal
experience necessary to obtain the State Certified General Appraiser license.
Under current Michigan regulations, an aspiring appraiser must find a supervisor to work
with for anywhere from six to eighteen months. However, many aspiring appraisers have
encountered difficulty in finding a supervisor. History shows us that the inability to find a
supervisor is one of the highest barriers to entry into the appraisal profession. This has
resulted in a significant decline in the number of people interested in pursuing real estate
appraisal as a career. Further, research has shown that the inability to find a supervisor
disproportionately impacts people of color. As such, the supervisor/trainee model has
contributed to the profession being 98% white.
PAREA was incorporated into the RPAQC by the AQB effective on January 1, 2021.
PAREA provides another pathway for aspiring appraisers to fulfill their experience
requirements to become an appraiser by taking advantage of technology. PAREA is
designed to offer practical experience in a virtual environment combining appraisal theory
and methodology in real-world simulations. This experience can be provided through a
wide range of online and virtual reality simulations.