STATE OF FLORIDA
DIVISION OF ADMINISTRATIVE HEARINGS
DEPARTMENT OF BUSINESS AND ) PROFESSIONAL REGULATION, DIVISION ) OF REAL ESTATE,
)
Petitioner, )
)
vs. ) Case No. 96-3672
)
JOHN E. POLK, )
)
Respondent. )
)
RECOMMENDED ORDER
Robert E. Meale, Administrative Law Judge of the Division of Administrative Hearings, conducted the final hearing on August 26, 1997, in Sebring, Florida.
APPEARANCES
For Petitioner: Attorney Steven W. Johnson
Department of Business and Professional Post Office Box 1900
Orlando, Florida 32802-1900
For Respondent: Attorney J. Wendell Whitehouse
445 South Commerce Avenue Sebring, Florida 33870
STATEMENT OF THE ISSUE
The issue is whether Respondent violated a standard for the development or communication of a real estate appraisal, in violation of the Uniform Standards of Professional Appraisal Practice and Section 475.624(14), Florida Statutes, and, if so, what penalty should be imposed.
PRELIMINARY STATEMENT
By Administrative Complaint dated March 7, 1996, Petitioner alleged that Respondent appraised a residential property on December 30, 1994, using a restricted report format. He allegedly estimated the market value as between $60,000 and
$70,000.
The Administrative Complaint alleges that Respondent invoked the departure provision of the Uniform Standards of Professional Appraising Practice without describing precisely the actual departures. The Administrative Complaint alleges that Respondent estimated the market value using subjective and misleading variables, such as the cost approach and Respondent's estimate of market value. The Administrative Complaint alleges that Respondent failed to state clearly the effective date of the report and failed to state the highest and best use of the property.
Count I of the Administrative Complaint alleges that Respondent thereby violated Section 475.624(14). Petitioner dismissed Count II at the hearing.
Respondent demanded a formal hearing. At the hearing, Petitioner called two witnesses and offered into evidence three exhibits. Respondent called two witnesses and offered into evidence 16 exhibits. All exhibits were admitted.
The court reporter filed the transcript on September 4, 1997.
FINDINGS OF FACT
Respondent is a certified general real estate appraiser, holding license number 0000157.
Respondent has worked as an appraiser for 15 years. He is a residential member of the Appraisal Institute. He attends two or three seminars annually to keep current with developments in his field.
Effective July 1, 1994, the Appraisal Standards Board of The Appraisal Foundation relaxed the requirements in its Uniform Standards of Professional Appraisal Practice (USPAP) for appraisals performed by appraiser. The Board recognized limited restricted appraisals as an acceptable alternative to a complete appraisal. The mid-year change was in response to federal legislation relieving banks of the requirement of using only certified appraisals for certain properties whose market values did not exceed stated thresholds. As authorized by the new legislation, banks were authorized to use evaluations by real estate brokers instead of more expensive, complete appraisals required by the USPAP.
Respondent diligently attempted to learn more about this new option, after it became available. The first course near
Sebring was in August 1994 in St. Petersburg. Respondent and another Sebring appraiser attended the course. The Appraisal Institute, which is not affiliated with the Appraisal Standards Board or The Appraisal Foundation, sponsored the course.
Respondent was chagrined to discover at the seminar that the Appraisal Standards Board had not yet promulgated a form or issued advisory opinions for the new limited restricted appraisal. Until the Appraisal Standards Board issued explanatory material in 1995, the primary source for information was the Appraisal Institute.
Returning from the course, Respondent and his colleague worked 40-60 hours trying to develop appraisal report forms that would satisfy the new requirements for limited restricted reports. As late as the spring of 1996, professional publications were reporting that sophisticated appraisal clients, such as lenders and attorneys, and appraisers themselves were confused by the appraisal types and reporting options authorized by the mid-year USPAP changes.
Since the Florida Legislature adopted the USPAP in 1991 as part of the law governing certified real estate appraisers, the Appraisal Standards Board has made substantial changes to the minimum requirements for appraising and appraisals, as set forth in the USPAP. The record contains no version of the USPAP prior to January 1, 1994, but it is likely that the minimum
requirements in effect when the Legislature adopted the USPAP permitted letter opinions of value.
This finding as to the USPAP requirements in 1991 is based on Statement No. 7, which is discussed below. Statement No. 7 warns that letter opinions of value do not comply with USPAP and "should" be eliminated. Unless it has taken the Appraisal Standards Board over three years to communicate this simple prohibition to appraisers, the prohibition followed the Legislature's adoption of the USPAP. In any event, Petitioner has not proved that the more restrictive standards in effect on January 1, 1994, were in effect in 1991.
The more restrictive USPAP standards in effect on January 1, 1994 (1994 USPAP), limited appraisals to one type of report. The 1994 USPAP permitted only what was later identified in the mid-year revision as the Self-Contained Appraisal Report.
1994 USPAP Rule 2-2 provided:
Each written real property appraisal report must:
identify and describe the real estate being appraised;
identify the real property interest being appraised;
state the purpose of the appraisal;
define the value to be estimated;
set forth the effective date of the appraisal and the date of the report;
describe the extent of the process of collecting, confirming, and reporting data;
set forth all assumptions and limiting conditions that affect the analyses, opinions, and conclusions;
set forth the information considered, the appraisal procedures followed, and the
reasoning that supports the analyses, opinions, and conclusions;
set forth the Appraiser's opinion of the highest and best use of the real estate, when such an opinion is necessary and appropriate;
explain and support the exclusion of any of the usual valuation approaches;
set forth any additional information that may be appropriate to show compliance with or clearly identify and explain permitted departures from, the requirements of Standard [Rule] 1;
include a signed certification in accordance with standards Rule 2-3.
(Footnotes, comments, and one explanatory statement are omitted.)
Effective July 1, 1994, USPAP (Revised USPAP) Rule 2-2 provided:
Each written real property appraisal report must be prepared under one of the following three options and prominently state which option is used: Self-Contained Appraisal Report, Summary Appraisal Report or Restricted Appraisal Report.
Comment: The essential difference among the three options is in the use and application of the terms describe, summarize and state. Describe is used to connote a comprehensive level of detail in the presentation of information. Summarize is used to connote a more concise presentation of information.
State is used to connote the minimal presentation of information.
The self-contained Report must:
identify and describe the real estate being appraised;
state the real property interest being appraised;
state the purpose and intended use of the appraisal;
define the value to be estimated;
state the effective date of the appraisal and the date of the report;
Comment on (iii), (iv) and (v):
These three requirements call for clear disclosure to the reader of a report the "who, why, what and when" surrounding the appraisal . . . . Defining the value to be estimated requires both an appropriately referenced definition and any comments needed to clearly indicate for the reader how the definition is being applied [See Standards Rule 1- 2(b)]. The effective date of the appraisal establishes the context for the value estimate, while the date of the report indicates whether the perspective of the appraiser on the market conditions as of the effective date of the appraisal was prospective, current, or retrospective. Reiteration of the date of the report and the effective date of the appraisal at various stages of the report in tandem is important for the clear understanding of the reader whenever market conditions on the date of the report are different from market conditions on the effective date of the appraisal.
state the extent of the process of collecting, confirming, and reporting data;
state the limiting conditions that affect the analyses, opinions, and conclusions;
describe the information considered, the appraisal procedures followed, and the reasoning that supports the analyses, opinions, and conclusions;
describe the appraiser's opinion of the highest and best use of the real estate, when such an opinion is necessary and appropriate;
explain and support the exclusion of any of the usual valuation approaches;
describe any additional information that may be appropriate to show compliance with, or clearly identify and explain permitted departures from the specific guidelines of standard [Rule] 1;
Comment: . . . When the Departure Provision is invoked, the assignment is deemed to be a Limited Appraisal. Use of the term Limited Appraisal makes it clear that the assignment involved something less than, or different from the work required by the specific guidelines. The report of a Limited Appraisal must contain a prominent section that clearly identifies the extent of the appraisal process performed and the departures taken
. . . .
include a signed certification in accordance with standards Rule 2-3.
The Summary Appraisal Report must:
Comment: The essential difference between the Self-Contained Appraisal Report and the Summary Appraisal Report is the level of detail of presentation. As examples:
a two-page narrative section with conclusion in a Self-Contained Appraisal Report might translate to a two paragraph section with the same conclusions in a Summary Appraisal Report; narrative presentation of data in a Self-Contained Appraisal Report might translate to tabular presentation of data in a Summary Appraisal Report.
identify and provide a summary description of the real estate being appraised;
[(ii)-(v) unchanged]
(vi) summarize the extent of the process of collecting, confirming, and reporting data.;
[(vii) unchanged]
summarize the information considered, the appraisal procedures followed, and the reasoning that supports the analyses, opinions, and conclusions;
summarize the appraiser's opinion of the highest and best use of the real estate, when such an opinion is necessary and appropriate;
[(x) unchanged]
(xi) summarize any additional information that may be appropriate to show compliance with, or clearly identify, and explain permitted departures from the specific guidelines of Standard [Rule]1; [(xii) unchanged]
The Restricted Appraisal Report must:
Comment: The essential difference between the Self-Contained and Summary Appraisal Reports and the Restricted Appraisal Report is both the level of detail of presentation and a use restriction that limits the reliance on the report to the client and considers anyone else using the report an unintended user.
identify the real estate being appraised;
[(ii)-(iii) unchanged]
(iv) state and reference a definition of the value to be estimated;
[(v) unchanged]
(vi) describe the extent of the process of collecting, confirming, and reporting data;
[(vii) unchanged]
(viii) state the appraisal procedures followed, state the value conclusion and reference the existence of specific file information in support of the conclusion;
Comment: An appraiser must maintain a specific, coherent file in support of a Restricted Appraisal Report. The contents of the file should mirror the contents of a Self-Contained Appraisal Report. The file should be available for inspection by the client, such third parties as may be authorized by due process of law, and a duly authorized professional peer review committee.
(xi) state the appraiser's opinion of the highest and best use of the real estate, when such an opinion is necessary and appropriate;
state the exclusion of any of the usual valuation approaches;
contain a prominent use restriction that limits reliance on the report to the client and warns that the report cannot be understood properly without additional information in the workfile of the appraiser, and clearly identify and explain any permitted departures from the specific guidelines of Standard [Rule] 1; [(xii) unchanged]
The Revised USPAP also contains Statement on Appraisal Standards No. 7, which was issued March 22, 1994. The Appraisal Standards Board issues statements for "clarification, interpretation, explanation or elaboration of the . . . USPAP. Statements have the full weight of a standards rule "
Statement No. 7 answers the question of when an appraiser may provide something less than a complete appraisal, such as a limited appraisal or letter opinion of value. Although issued as part of the Revised USPAP, Statement No. 7 predates the Revised USPAP, so the Appraisal Standards Board necessarily was interpreting the rules in effect on March 22, 1994--prior to the July 1 revision.
Despite the fact that Statement No. 7 precedes the Revised USPAP, the Appraisal Standards Board cited the definition of "appraisal" that is found in the Revised USPAP, not the more restrictive definition found in the 1994 USPAP.
Under the newer definition, a "Complete Appraisal" is the estimating or estimate of value without invoking the
”Departure Provision." A "Limited Appraisal" is the estimating or estimate of value invoking the Departure Provision.
The "Departure Provision" is found in the 1994 USPAP and the Revised USPAP, with few changes between them. As stated in the Revised USPAP, the Departure Provision "permits limited departures from sections of the Uniform Standards that are classified as specific guidelines rather than binding requirements."
Citing the binding requirements, which include Rule 2- 2, the new Departure Provision adds that an appraiser "may enter into an agreement to perform an assignment that calls for something less than, or different from, the work that would otherwise be required by the specific guidelines," if three conditions are met. The conditions are that the limited appraisal not be misleading or confusing, the appraisal report "will clearly identify and explain the departure(s)" (in the 1994 USPAP, this condition is that the limited appraisal "will state the limited or differing scope of [work]"), and the client agrees to the limited appraisal (this is new in the Revised USPAP, but mentioned in Statement No. 7).
Statement No. 7 describes the three report options first approved three months later in the Revised USPAP. They are the Self-Contained Appraisal Report, Summary Appraisal Report, and Restricted Appraisal Report.
Statement No. 7 briefly describes Rules 1-2, 1-3, 1-4, and 2-2 as applicable to the appraisal process (Rules 1-2, 1-3 and 1-4) and the appraisal report (Rule 2-2). Statement No. 7 notes that Rules 1-2, 1-3, and 1-4 contain guidelines, from which departures are permissible, but Rule 2-2 is a binding requirement, from which departures are prohibited.
Statement No. 7 describes a logical scheme for the appraising process, which is either Complete or Limited, and appraisal reports, which are Self-Contained, Summary, or Restricted. A report is also Complete or Limited, depending on the extent of the appraising process underlying the report. Obviously, the most extensive job is a Complete Self-Contained Appraisal Report, and the least extensive is a Limited Restricted Appraisal Report. Unfortunately, Statement No. 7 raises a question as to the exhaustiveness of these classifications when it describes the "Letter Opinion of Value" as an obsolete device that "does not comply with USPAP, and should be eliminated from appraisal practice" (emphasis supplied).
On December 30, 1994, Respondent submitted a document to James Northrup. The document is entitled, Limited Appraisal and Restricted Appraisal Report. The reference clause on the first page of the document identifies the subject property by street address and tax parcel number. The document is dated December 30, 1994.
The document states that Respondent has invoked the departure provision described in the definitions, Standard [Rule] 2, and Standard [Rule] 3 of USPAP. Strictly speaking, this statement is incorrect, although not misleading. The departure provisions of the 1994 and Revised USPAPs allow appraisers to depart from certain USPAP requirements under certain conditions. Neither version of the USPAP permitted departures from Rule 2-2.
The December 30 document states that it is for the exclusive use of Mr. Northrup, and third parties may not rely upon it. The document states that Respondent met Mr. Northrup and his real estate broker at the subject property "to establish a range of values for negotiating a potential purchase contract."
The December 30 document states that the value of the subject property is "estimated based on the average estimated market value to cost approach ratio." By sampling 35 appraisals, Respondent found an average estimated market value/cost approach ratio of 100 percent-105 percent with one standard deviation being 7.3 percent.
The December 30 document continues, "I estimated the value of the subject property by multiplying the cost approach
$66,300 by the average (mean) estimated market value/cost approach ratio of 1.00 to 1.05 giving an estimated value range for the subject property of $66,000 to $70,000."
The December 20 document concludes with the following warnings:
There is an approximately 68 percent probability that my estimate is not more than
7.3 [percent] (1 standard deviation) in error and approximately a 95 [percent] (2 standard deviations) probability that my estimate is not more than 14.6 [percent] in error.
The reader is cautioned that there is a 5 [percent] statistical probability that the error will be greater than 14.6 [percent] and also that a greater error is possible because of sampling errors.
The reader is also cautioned that a more detailed, self-contained market report may have a substantially different estimated market value. This report should not be relied upon by a third party and is for the exclusive use of James Northrup who understands the limitations of this report.
Attached to the December 30 document are a number of documents. The first is a general information sheet with a legal description and other descriptive information, including that the property is zoned R-1A (residential) and the neighborhood consists of only single-family housing. Another sheet details the cost approach and warns that "a more detailed, self-contained appraisal report may have a substantially different estimated market value."
Another attachment defines market value to assure that the appraiser has estimated the land at its highest and best use and the improvements at their contributory value. The final page of the final attachment bears Respondent's signature and the date signed, which is December 30, 1994.
Petitioner has raised in the Administrative Complaint four factual issues, which are also discussed in its proposed
recommended order. This order addresses below Petitioner's failure to identify specific USPAP rules allegedly violated by Respondent. The findings below are made solely in the event that the Board of Real Estate Appraisers revises the conclusions of law that the 1994 USPAP and Revised USPAP are inapplicable.
Two factual issues are clear-cut. These are Petitioner's alleged failures to state clearly the effective date of the report and to state the highest and best use of the property.
There are no material differences in the 1994 USPAP and Revised USPAP provisions governing these two points. Both versions require the report to state the effective date of the appraisal and the date of the report and to summarize the appraiser's opinion of the highest and best use, when necessary and appropriate.
The December 30 document states that Respondent inspected the property on the date of the report. The report is dated and signed December 30, 1994. There are no other possible dates for the effective date of the report. This is a simple residential appraisal in a stable neighborhood in Sebring, not a 600-unit apartment building on South Beach. Under the circumstances, the effective date of December 30 document is clear.
For largely the same reasons, Respondent did not violate any USPAP requirement regarding highest and best use. In
addition to the factors cited in the preceding paragraph, the property's R-1A zoning, location (as revealed on the attached location map) at least a couple of blocks from the nearest major road, and Respondent's intimate knowledge of Sebring and its slow-growth characteristics relieved Respondent of the necessity of stating the property's highest and best use.
The third factual allegation is that Respondent estimated market value using subjective and misleading variables, such as the cost approach and Respondent's estimate of market value.
To the extent that this allegation asserts that Respondent's statistical information is misleading, the allegation is untrue. The statistical information emphasizes the necessarily probabilistic nature of appraising. The statistical disclosure limits confidence in the result; it does not raise such confidence.
Respondent did not use misleading variables, nor were his variables more subjective than the variables present in any appraisal. Drawing on his construction experience, Respondent emphasizes the cost approach, but tempers his findings based on his extensive knowledge of comparable sales in the small community of Sebring. An income approach would not likely yield much additional useful information.
The pleading deficiencies discussed below are especially prominent as to the third allegation. If the
implication here is that Respondent violated Rule 2-2, the problem is identifying what provision. Revised USPAP Rule 2- 2(c)(viii) requires a Restricted Appraisal Report to the state the appraisal procedures followed and the value conclusion.
Revised USPAP Rule 2-2(c)(x) requires a Restricted Appraisal Report to state the exclusion of any of the usual valuation approaches. If Petitioner intended to notify Respondent through the Administrative Complaint that he was defending charges that he violated either of these rules--neither of which is mentioned in Petitioner's proposed recommended order--Petitioner did not adequately do so.
In any event, the requirements of Rule 2-2 are formal in nature. They do not mandate that an appraiser adopt a specific valuation approach; rather, they require disclosure of the approaches excluded. Rule 2-2 leaves the appraiser considerable latitude within which to exercise his or her professional judgment.
The fourth allegation is that Respondent invoked the departure provisions without describing precisely the exact departures.
The December 30 document invokes the departure provision described in the definitions, Rule 2, and Rule 3. This appears to be inadequately considered boilerplate, at least as to Rule 2. The 1994 USPAP and Revised USPAP authorize departure only from Rule 2-4, which applies to oral appraisal reports.
Likewise, both the 1994 USPAP and Revised USPAP prohibit departure from either of the two rules constituting Rule 3.
Respondent's reference to the definition section is likewise without effect. The definition section authorizes departures from all guidelines, but both USPAP versions require the appraiser to identify from which guidelines he is departing.
However, an inadequate invocation of the departure provisions is harmless if the appraiser never departs from any guidelines. Petitioner never alleged from which the guidelines Respondent departed, nor did Petitioner discuss such guidelines in its proposed recommended order. This case really involves only Rule 2-2; no departures from this rule are permissible, and Respondent made none.
CONCLUSIONS OF LAW
The Division of Administrative Hearings has jurisdiction over the subject matter under Section 120.57(1).
Section 475.624(14) authorizes the Florida Real Estate Appraisal Board to impose discipline for the violation of "any standard for the development or communication of a real estate appraisal or any other provision of the [USPAP]."
Section 475.611(1)(m) defines USPAP as "the most recent standards approved and adopted by the Appraisal Standards Board of the Appraisal Foundation."
Petitioner must prove the material allegations by clear and convincing evidence. Ferris v. Turlington, 510 So. 2d 292, (Fla. 1987).
The Legislature enacted Sections 475.624(14) and 475.611(1)(m) in 1991. The most recent USPAP at the time was likely the 1991 USPAP.
Petitioner argues that Section 475.611(1)(m) reveals Legislative intent to incorporate subsequent changes to the USPAP. However, clearer language than this is necessary to conclude that the Legislature has delegated its quasi-penal legislative authority, especially where the delegation is not to an executive agency, but to a private, professional organization. Disciplinary statutes are construed against the agency.
By contrast, the Legislature is explicit in the Florida Income Tax Code when attempting to enact future amendments to the Federal Internal Revenue Code. Section 220.03(3) and (4) enacts such amendments "to the same extent as if such amendment has been adopted by the Legislature." Even so, the Legislature annually amends Section 220.03(1)(m) to define the Internal Revenue Code as amended through the current year.
Petitioner's argument for incorporating prospective amendments into the USPAP without Legislative enactment raises difficult practical questions, in addition to the delegation issue. Even a diligent appraiser like Respondent may find it difficult to stay informed of major changes in the USPAP, which
may occur at anytime. Statement No. 7 implies that major changes to Rule 2-2 took place months prior to the July 1 revision. What may have been a careless use of the word, "should" undermines the supposedly obligatory nature of the "prohibition" against letter opinions of value. There is a fairness question when the USPAP Standards are not immediately disseminated when revised, revised from time to time (rather than annually), and phrased in language undermining their mandatory nature.
For these reasons, Florida law adopts only the USPAP Standards in effect in 1991. Petitioner did not prove the contents of the 1991 USPAP and thus failed to prove a violation of any of its rules.
If the Board of Real Estate Appraisers rejects these conclusions of law, the Revised USPAP is applicable, but Petitioner failed to prove the material allegations.
First, for the reasons already discussed, Petitioner failed to prove the material allegations of the Administrative Complaint.
Second, the allegations are impermissibly vague and fail to inform Respondent of the nature of the charges. If Petitioner intends to prove a violation of USPAP provisions, the Administrative Complaint must identify the specific acts or omissions that violated specific rules. This exercise will sharpen the presentation of evidence by both sides and might result in the presentation of cases in which the violations of
the USPAP are brought into sharper relief. Although clearly not a precondition for a USPAP violation, an indefensible estimated value would also be helpful in highlighting the violation by illustrating the kind of distorted result that the USPAP is intended to prevent.
RECOMMENDED
It is
RECOMMENDED that the Florida Board of Real Estate Appraisers enter a Final Order dismissing the Administrative Complaint.
DONE AND ORDERED this 3rd day of November, 1997, in Tallahassee, Leon County, Florida.
ROBERT E. MEALE
Administrative Law Judge
Division of Administrative Hearings The DeSoto Building
1230 Apalachee Parkway
Tallahassee, Florida 32399-3060
(904) 488-9675 SUNCOM 278-9675
Fax Filing (904) 921-6847
Filed with the Clerk of the Division of Administrative Hearings this 3rd day of November, 1997.
COPIES FURNISHED:
Attorney Steven W. Johnson
Department of Business and Professional Post Office Box 1900
Orlando, Florida 32802-1900
Attorney J. Wendell Whitehouse
445 South Commerce Avenue Sebring, Florida 33870
Lynda L. Goodgame, General Counsel
Department of Business and Professional Regulation 1940 North Monroe Street
Tallahassee, Florida 32399-0792
Henry M. Solares, Division Director Division of Real Estate
Department of Business and Professional Regulation Post Office Box 1900
Orlando, Florida 32802-1900
NOTICE OF RIGHT TO SUBMIT EXCEPTIONS
All parties have the right to submit written exceptions within 15 days from the date of this Recommended Order. Any exceptions to this Recommended Order must be filed with the agency that will issue the Final Order in this case.
| Issue Date | Proceedings |
|---|---|
| Jul. 15, 2004 | Final Order filed. |
| Nov. 03, 1997 | Recommended Order sent out. CASE CLOSED. Hearing held 08/26/97. |
| Oct. 24, 1997 | Respondent`s Proposed Recommended Order received. |
| Sep. 15, 1997 | Petitioner`s Proposed Recommended Order received. |
| Sep. 04, 1997 | Transcript filed. |
| Sep. 04, 1997 | Petitioner`s Memorandum of Law (filed via facsimile) received. |
| Aug. 26, 1997 | CASE STATUS: Hearing Held. |
| Aug. 22, 1997 | (Petitioner) Unilateral Compliance With Pre-Hearing Order w/exhibits filed. |
| Jun. 30, 1997 | Notice of Hearing sent out. (hearing set for 8/26/97; 9:00am; Sebring) |
| Jun. 20, 1997 | (Petitioner) Status Report (filed via facsimile). |
| Feb. 24, 1997 | Order of Continuing Case In Abeyance sent out. (case in abeyance until 6/2/97) |
| Feb. 21, 1997 | Status Report (Petitioner) filed. |
| Nov. 15, 1996 | Order of Abeyance and Status Report sent out. (Parties to file mutually agreeable hearing dates by 2/20/97) |
| Nov. 14, 1996 | (Petitioner) Motion to Continue and Hold Case In Abeyance (filed via facsimile). |
| Sep. 11, 1996 | Notice of Hearing sent out. (hearing set for 11/20/96; 9:00am; Sebring) |
| Sep. 11, 1996 | Prehearing Order sent out. |
| Sep. 03, 1996 | (Petitioner) Unilateral Response to Initial Order filed. |
| Aug. 13, 1996 | Initial Order issued. |
| Aug. 06, 1996 | Agency referral letter; Petition for Formal Hearing, (Exhibits); Petitioner`s First Request for Admissions and Interrogatories; Administrative Complaint filed. |
| Issue Date | Document | Summary |
|---|---|---|
| Dec. 22, 1997 | Agency Final Order | |
| Nov. 03, 1997 | Recommended Order | Petitioner failed to prove appraiser violated Uniform Standards of Professional Appraisal Practice (USPAP) or that legislation enacted USPAP revisions after 1991. |
