The licensee exception in Georgia
Georgia's appraiser law does not apply to a licensee who, in the ordinary course of brokerage business, gives a broker's price opinion, competitive market analysis, or other opinion as to the recommended listing, lease, rental, or purchase price — provided it is not referred to as an appraisal. That is a Georgia rule, and the naming condition is the whole condition.
A salesperson giving a seller a suggested list price acts lawfully. Charging a fee does not make it unlawful, and no certified appraiser must review or sign it. Call it an appraisal, though, and the exception is gone.
Who must appraise, by transaction value
Thresholds govern federally related transactions:
- Residential transactions of $400,000 or less are exempt from the appraisal requirement, but an evaluation is still required. "No appraisal" never means "no valuation."
- A state licensed appraiser suffices for non-complex residential transactions above the threshold.
- A state certified appraiser is required for complex 1-to-4 family residential appraisals over $400,000, for any federally related transaction of $1,000,000 or more, and for commercial transactions over $500,000.
A complex appraisal is one where the property, the form of ownership, or market conditions are atypical. The exam trap: on a complex residence at $600,000, "a licensed appraiser, because the loan is under $1,000,000" is wrong. The old $250,000 threshold was raised to $400,000 in 2019.
Where a BPO may not go
For the purchase of a consumer's principal dwelling, a broker price opinion may not be used as the primary basis to determine value for originating a residential mortgage loan secured by that property. A BPO cannot serve as the evaluation either, because a valuation method that provides a sales or list price cannot be used as an evaluation. An interior inspection does not cure it.
Appraiser experience credit
Georgia excludes market value estimates made as a licensee in connection with the listing or sale of real estate from appraiser experience credit. CMA and BPO hours earn zero credit — not full, not half, and no certified appraiser's co-signature converts them.