Florida Real Estate Appraiser & Appraisal Firm License Defense
An appraisal complaint is not the same as a disagreement over value. The report, methodology, assignment conditions, and cited standard determine the regulatory issues.
Understand the Notice Before You Respond
Kafrouni Law represents eligible real estate appraisal professionals and regulated businesses in DBPR investigations and administrative enforcement matters. A FREAB matter can involve USPAP, data verification, inspections, report certifications, trainee supervision, scope of work, or appraisal management company obligations. Effective defense requires identification of the edition of the standards applicable to the assignment, the workfile and the actual evidence.
A disputed valuation should be evaluated against the assignment record and governing USPAP standards, not treated as automatic proof of misconduct.
Issues We Evaluate
USPAP and appraisal report allegations
Evaluate the cited standard, applicable edition, assignment scope and documentary support.
Inspection and workfile issues
Examine inspection records, photographs, correspondence, data sources and file retention.
Supervision and trainee concerns
Analyze the supervising appraiser’s obligations and the actual role of each participant.
Appraisal management companies
Assess license and business obligations, firm policies and the conduct attributed to the company.
Administrative Complaints
Develop legal defenses, evaluate professional standards evidence, and assess resolution options.
How We Evaluate Your Matter
Preserve the workfile
Collect the actual report, associated workfile, engagement instructions, revisions and communications.
Check the governing standards
Identify the USPAP edition and statutory or rule provision that applied to the assignment date.
Evaluate the allegation
Separate professional judgment issues from potential standards violations and determine whether expert analysis is needed.
Documents that help us assess the matter
- FREAB investigative notice and complaint
- Complete appraisal report and original workfile
- Inspection materials, photographs and assignment conditions
- Supervisory or appraisal management communications
Frequently Asked Questions
Does a low or high valuation prove a violation?
No. A disputed value alone is not a substitute for analysis under the standards applicable to the appraisal.
Which USPAP edition applies?
That depends on when the appraisal was performed and the applicable regulatory requirements.
Does FREAB regulate appraisal management companies?
Florida has a regulatory framework for appraisal management companies as well as appraisers; the exact alleged violation must be identified.
What should I bring?
The notice, appraisal report, workfile index, assignment communications, supervision records if relevant, and response deadline.
Is disagreement with an appraisal value proof of misconduct?
Not by itself. The actual report, assignment conditions, applicable standards and investigative evidence require evaluation.
Which version of USPAP is relevant?
The standards applicable to the work should be assessed based on the assignment date and the governing regulatory framework.
Why preserve the complete workfile?
The original workfile may show what information was considered, the scope of work, supervisory records and contemporaneous support for the report.
Discuss Your Regulatory Matter
Have the notice reviewed before deciding how to respond. Prepare the original agency notice, your license details, the date received, applicable deadlines, and relevant documentation.
Matters are assessed individually for legal scope, conflicts, and any applicable representation restrictions.