Christine McEntire, Director
Oklahoma Real Estate Appraiser Board
400 N.E. 50th St.
Oklahoma City, OK 73105-1816
Re: Louise Brewer, Complaint Nos. 22-018, 22-018A
Dear Director McEntire:
This office has received your request for a written Attorney General Opinion regarding action that the Oklahoma Real Estate Appraiser Board intends to take in cases 22-018 and 22-018A.
The Oklahoma Certified Real Estate Appraisers Act authorizes the Board, upon finding a violation of the Act or Board rules, to revoke an appraiser’s certificate and order an appraiser to pay legal fees and costs expended by the Board. See 59 O.S.2021, § 858-723(A)(1), (9). The Act requires licensed appraisers to adhere to the Uniform Standards of Professional Appraisal Practice (“USPAP”), which contains professional requirements pertaining to ethics, competency, and scope of work. 59 O.S.2021, § 858-726. The Board may discipline licensees who (1) violate “the standards for the development or communication of real estate appraisals as provided in the . . . Act[,]” (2) fail or refuse to “exercise reasonable diligence in developing an appraisal, preparing an appraisal report or communicating an appraisal[,]” (3) are negligent or incompetent “in developing an appraisal, in preparing an appraisal report, or in communicating an appraisal[,] (4) violate any provisions of the Act, or (5) fail to submit appraiser’s records for Board inspection. 59 O.S.2021, §§ 858-723(C)(6–9), 858-729(C).
According to a Board complaint, Respondent performed an appraisal in February 2021 that failed to meet the required USPAP standards, resulting in a misleading, non-credible appraisal report supported by inadequate, incomplete, or no analysis. The Board proposes to revoke Respondent’s license and require Respondent to pay legal fees and costs, not to exceed $3,000. Failure to comply with these requirements will result in Respondent’s appraisal credential being suspended. The Board may reasonably believe that the proposed action is necessary to prevent future violations.
It is, therefore, the official opinion of the Attorney General that the Oklahoma Real Estate Appraiser Board has adequate support for the conclusion that this action advances the State’s policy to uphold standards of competency and professionalism among real estate appraisers.
ROB JOHNSON
General Counsel
