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DLR Prematurely (Illegally?) Waives National Exam for Appraiser-Trainees

The state’s Appraiser Certification Program has told at least one aspiring appraisers that applicants don’t have to take the national appraiser-trainee exam to qualify for the State-Registered Appraiser credential. In telling applicants they can skip that exam, the state’s Appraiser Certification Program appears to be violating existing rules.

On October 21, Professional Appraisers Association of South Dakota President Sandra Gresh wrote to newly appointed Appraiser Certification Program director Scott Amundson to express PAASD’s opposition to three rule changes that ACP has proposed in apparent support of Governor Kristi Noem’s push to “streamline” appraiser certification. One of those rule changes proposes eliminating the requirement that appraiser-trainees pass a national appraiser-trainee examination before obtaining the State-Registered Appraiser credential and beginning to log experience hours. According to Gresh’s letter, a public hearing was scheduled for October 7 on those changes; PAASD is asking the Legislature’s Interim Rules Review Committee to block those changes at its November 15 meeting.

But according to Gresh, the Department of Labor and Regulation under which Amundson and the ACP operate appear to have implemented the exam rule change on its own as early as August:

PAASD is also concerned about the provisions of this proposed rule change which have apparently been implemented by the ACP before legislative authority and approval has been received. For example, the email on page 9 of this document clearly shows that the ACP has chosen to disregard the existing administrative rule requiring the administration of a national trainee exam before issuing the State-Registered Appraiser credential. Our organization would be interested in the rationale for this action and the number of trainees that have been issued a State-Registered Appraiser credential without taking the national trainee exam—despite the requirement to do so [Sandra Gresh, letter to Scott Amundson, 2021.10.21, p. 7].

Here’s the email to which Gresh refers, and August 26 message to Melissa L. Hill concerning her State-Registered Appraiser credential, which DLP senior secretary Anna Bennett says was issued with no exam required on August 25:

Anna Bennett, SD DLR, email to Melissa L. Hill, 2021.08.26; included in Gresh, 2021.10.21.
Anna Bennett, SD DLR, email to Melissa L. Hill, 2021.08.26; included in Gresh, 2021.10.21, p. 9.

The Department of Labor and Regulation cannot waive an exam required by its own rules until the Legislature says it can. The Legislature has not issued any such permission. We can thus understand PAASD’s concern that the Department may be illegally registering appraiser-trainees who have not fulfilled every legal requirement to receive that privilege.


  1. Porter Lansing 2021-10-28 15:13

    That state, though.

  2. ArloBlundt 2021-10-28 15:29

    Well…this decision by a Department of State government has cheapened and put in question every home and property appraisal done by appraisers in this state whether they have passed the federal exam or been “waived” through illegally by the state. The buyer has no way of knowing the professional status, real professional status of the appraiser or the validity of the appraisal. If allowed to continue, after several years, it will put the value of every piece of property in the state in question. It will lead to rampant speculation and market manipulation and it is irresponsible. Appraisers who value their professional status have every right to be concerned as should be every property owner and prospective buyer.

  3. Cory Allen Heidelberger Post author | 2021-10-28 16:25

    The DLR-ACP website still says the exam is required for the entry-level state registered appraiser.

  4. Cory Allen Heidelberger Post author | 2021-10-28 16:31

    The ACP Appraiser Roster shows Ms. Hill and six individuals with credential ID numbers that are higher than Hill’s. I don’t know if these numbers are sequential.

  5. Mark Anderson 2021-10-28 17:34

    Come on Cory, you know Noem knows appraising is as easy as riding a horse. Her daughter does it and she failed the test. It’s waving the flag while you ride that separates the Presidential material from the others. I mean, Abbott can’t walk so he’s physically like FDR, and DeSantis was a shortstop, she’s in with Flynn.
    I don’t care about appraisals one bit since we’re never leaving our house and I’ve been making it entirely ours for over a year. I’d say done in six months. The bathrooms were a beach, got them done, put in some really interesting furniture we found to set the sinks on. One glass, one stone and one semi regular. The ceiling of one is where I let my Frank Gehry loose. Was going to do that in the kitchen, but since it’s just me, simply raised it foot and a half. Ripped out all the rugs and put in Spanish porcelain tile everywhere. Just disassembled the pool table today, luckily the slate was in threes. We’ve lived in this place over 20 years and it’s finally ours. The pool tables going to the studio where it should have been. You can do anything with the internet. The house is so personalized now it’s probably gone down in value but I don’t care.

  6. RST Tribal Member 2021-10-28 22:19

    Lawyers, hookers and appraisers are all fee for service. You have a need, you have money, you get the service. One is licensed after going thru too many years of college, then passing a tough test, to stay licensed a few hours of updating is needed periodically. The other is certified after a series of training, and shadowing an established appraiser after taking a few tests. The last one needs a pimp.

    The Bully Gov has taken to pimping out appraisal certificates, just like the second oldest profession that existed in Deadwood before inbred Republicans were caught with their legislative pants down around their ankles a few decades ago.

    Good luck to PAASD. The lesson learned, “you get what you vote in”. In about a year there is a chance to rid the state of the Queen Gov aka America’s Governor aka Bully Gov, now proudly titled Pimp Gov. Or, the first oldest profession licensing will be streamlined with a 3 day course in How To Be A Lawyer taught by 45 in and around the stoned faces or Florida depending on the time of year. The internship will be managing a trust somewhere in the state.

  7. Brian SF 2021-10-28 23:41

    When our house was “inspected” he missed so many things. Same with two others on my block. Less qualified inspectors is the last thing homebuyers need.

  8. V 2021-10-29 06:37

    Better watch out, Careless Kristi will streamline all the professions in SD except teaching of course, where she’d probably like to pile additional courses.

    I think the next time I have my house appraised, I’ll tell the bank to get 3 appraisers and we’ll average it out.

    Hey, if appraisers invest less in obtaining their license, their fees should be reduced GREATLY.

  9. buckobear 2021-10-29 09:45

    Next up, “Board Certification” as a brain surgeon no longer required. ……… a political $ contribution is all that’s needed.

  10. Cory Allen Heidelberger Post author | 2021-10-29 12:50

    Buckobear, if one of Kristi’s kids decides to go to med school, watch out!

    I have to wonder to what extent Noem thinks she has a workable policy solution here. you can’t just blindly lower the standards for entering a profession. You have to have some barriers to entry to ensure people can do those jobs right.

    I also wonder how do Department of labor thinks I can get by with implementing a rule change without approval from the legislature. What will it take to hold the department accountable? Will some property buyer or property seller have to get ripped off and sue the appraiser for a bad appraisal? Could a dissatisfied buyer or seller take the department to court for negligence in registering a trainee appraiser? What oversight remains to ensure that these new state-registered appraisers don’t cause harm to participants in the real estate market?

  11. Guy 2021-10-29 14:11

    I want to hear Sherry Bren’s side of the story.

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