ISSUE: An applicant for State Licensed, Certified Residential, or Certified General Appraiser license/certification originally took and passed a license/certification examination. Now that all Transitional Licenses have expired, is the applicant required to take another license/certification examination?

Massachusetts General Law Chapter 112, section 180 C states, in part "Until January first, nineteen hundred and ninety-three, any person who passes the requisite state administered licensing examination but who lacks either the requisite education or requisite experience required for licensing under subdivision B may apply for and receive a transitional license, valid for two years from the date of issuance and delay satisfaction of the education or experience requirement until expiration of the transitional license. If, by the time of expiration of such transitional license, such person presents evidence satisfactory to the board that he has satisfied the education and experience requirements, a renewal license as a state-licensed real estate appraiser shall be issued…"

265 CMR 7.01 (4) states, in part "(a) A transitional license is valid for two years and is not renewable. Prior to its expiration, a transitional licensee may apply to upgrade his/her license to a state license provided that …"

The Real Property Appraiser Qualification Criteria and Interpretations of the Criteria (Criteria) as adopted by the Appraiser Qualifications Board of the Appraisal Foundation state, within each of the criteria for State Licensed, Certified General Appraiser, and Certified Residential Appraiser states, in part, "…Successful completion of the examination is valid for a period of 24 months…"

Therefore, Since all Massachusetts Transitional Licenses are expired and have been expired for more than twenty-four (24) months, all applicants who previously held a Transitional License and did not up-grade prior to its expiration MUST successfully complete an examination at the level of license sought by the applicant. Furthermore, since the Board adopts the Criteria for State Licensed, Certified Residential and Certified General Appraisers, there are no exceptions to this policy.