(a) Education requirements for New York State appraiser assistants. An applicant must satisfactorily complete the following courses within the five year period prior to the date of submission of an appraiser assistant application:

(1) Residential 5 (R-5) - Basic Appraisal Principles 30 hours

(2) Residential 6 (R-6) - Basic Appraisal Procedures 30 hours

(3) USPAP or its equivalent, as further defined in 15 hours

section 1103.7 of this Part

[(4) Residential 7 (R-7) - Residential Market Analysis 15 hours

and Highest and Best Use

(5) Residential 8 (R-8) - Residential Appraisal Site 15 hours

Valuation and Cost Approach

(6) Residential 9 (R-9) - Residential Sales Comparison 30 hours

and Income Approach

(7) Residential 10 (R-10) - Residential Report 15 hours

Writing and Case Studies

(8)] (4) Supervisory Appraiser/Trainee Appraiser Course 4 hours

Total [154] 79 hours

This statement is being submitted pursuant to subparagraph (i) of paragraph (b) of subdivision (1) of section 202 of the State Administrative Procedure Act and in support of the State Board of Real Estate Appraisal’s (“Board”) Notice of Proposed Rule Making to amend Paragraph (a) of Section 1103.2 of Title 19 of the Official Compilation of Codes, Rules and Regulations of the State of New York (“NYCRR”).

It is apparent from the nature and purpose of this rule that no person is likely to object to the adoption of the rule as written.

The Federal Appraisal Qualifications Board (the “AQB”), in accordance with the authority granted to said body pursuant to, inter alia, Title XI of the Financial Institutions Reform, Recovery and Enforcement Act of 1989 (Title XI), establishes minimum qualification standards for licensed real property appraisers. States are required to implement appraiser standards that are no less stringent than those issued by the AQB.

The instant proposal seeks to decrease current educational standards to conform to lower standards established by the AQB. By proposing this rule making, the Board seeks to make obtaining the entry level license (i.e., an appraiser assistant) easier by removing additional New York State educational standards that exceed applicable federal guidelines. In preparing this proposal, the Department of State (the “Department”) has found that other states already adhere to the AQB standards without imposing additional requirements. Based on the foregoing, the Board and the Department have determined that this proposal, which seeks to amend existing regulations to conform to existing lower federal standards, is non-controversial, is applicable in other jurisdictions and, therefore no person is likely to object to its adoption.

A Job Impact Statement is not required for the proposed regulatory amendments. It is apparent from the nature and the purpose of the proposed regulatory amendments that they will not have a substantial adverse impact on jobs and employment opportunities in either the public or private sectors. The proposed amendments will have a positive effect on employment opportunities by decreasing, consistent with existing federal guidelines, the education requirements to obtain an entry level license as an appraisal assistant.