Maryland Commission of Real Estate Appraisers, Appraisal Management Companies and Home Inspectors
The offices of the Commission of Real Estate Appraisers, Appraisal Management Companies and Home Inspectors are open and serving our customers through our online licensing resources, via e-mail and telephone, and by limited in-person appointments. Please note, walk-in assistance is not available. We can be reached using our contacts page for e-mail addresses and telephone numbers of individual staff members; or
Use Labor’s Central Scheduling System to meet with a representative from one of our boards or commissions. Please select the type of appointment you need from our list of available in-person services using the drop-down menu on the scheduler. You will receive an e-mail confirming the date and time of your appointment.
Appointments are available Monday through Friday, from 10:00 a.m. – 4:00 p.m. at our offices located at 1100 N Eutaw St. 5th floor, Baltimore, MD 21201. Please arrive at least 10 minutes early before your scheduled appointment time.
The Commission of Real Estate Appraisers, Appraisal Management Companies and Home Inspectors licenses and regulates individuals who perform real estate appraisal services in connection with federally related transactions. As defined in the federal Financial Institutions Reform, Recovery and Enforcement Act of 1989, this includes appraisal management companies.
The Commission regulates individuals who provide appraisal services pursuant to the provisions of Business Occupations and Professions Article, Annotated Code of Maryland, Title 16 and the Code of Maryland Regulations, Title 9, Subtitle 19.
Further, the Commission regulates individuals who provide home inspection services pursuant to the provisions of Business Occupations and Professions Article, Annotated Code of Maryland, Title 16 and Code of Maryland Regulations, Title 9, Subtitle 36.
The Commission also regulates appraisal management companies pursuant to the provisions of Business Occupations and Professions Article, Annotated Code of Maryland, Title 16 and Code of Maryland Regulations, Title 19, Subtitle 39.
Further, the Commission of Real Estate Appraisers, Appraisal Management Companies and Home Inspectors is proud to protect the public by ensuring professional competency of its licensees through fair and consistent enforcement of the Federal and State statutes and regulations.
News and Updates
It has come to the attention of the Maryland Commission of Real Estate Appraisers, Appraisal Management Companies, and Home Inspectors (“Commission”) that there may be confusion over where a supervising appraiser and trainee are supposed to sign an appraisal report and how a licensed or certified appraiser is to disclose assistance and third party contribution. A supervising appraiser is only to sign the "appraiser" section when they have completed an interior inspection of the property as per the certifications page 5 of 6 of the 1004URAR: "I performed a complete visual inspection of the interior and exterior areas of the subject property." If the supervising appraiser did not inspect the interior, they must sign in the "supervisor" section. See attached sample. Trainees, as well as supervisors that provide samples of appraisals incorrectly signed, may be subject to disciplinary action by the Commission pursuant to MD Ann. Code, Bus. Occ. & Prof. §16-701. Additionally, it is recommended that each supervising and trainee appraiser visit the state website and review how trainees' assistance is to be disclosed, see attached documents.
The Commission is also aware of the new Fannie Mae 1004 Hybrid and 1004 Desktop appraisal forms. Both utilize property data reports on which an appraiser would need to rely as a source. An appraiser preparing a desktop appraisal should refer to USPAP Standard 1 and Advisory Opinion 2. Ultimately the appraiser is responsible and liable for data collected by third parties.
All licensed home inspectors are expected to familiarize themselves with the regulations applicable to home inspectors services and, particularly, Home Inspector Code of Ethics and Minimum Standards of Practice. as set forth in Code of Maryland Regulations ("COMAR") 09.36.06.01-.04 and 09.36.07.01-.13, respectively. See Division of State Documents website. The Commission cautions any licensed home inspector who is employed or engaged by or through a realtor or real estate company to ensure that the home inspector be aware of and comply with mandatory disclosures to clients of the potential conflicts of interest, particularly those set forth in, but limited to, COMAR 09.36.06.01E, 02A(3), and .04A. A home inspector must promptly inform a client of any business association, interest, or circumstance that may influence the home inspector’s judgment or the quality of the home inspector’s service to the client, such as actual or perceived pressure to conceal a particular defect that could affect a potential buyer’s interest in the property and impair the real estate transaction. A home inspector may not accept or offer a commission or allowance, directly or indirectly, to or from another party dealing with the client in connection with home inspection services for which the home is responsible. A home inspector’s employment by or affiliation with a subsidiary of a real estate brokerage that receives part of the profit on the home inspection, could constitute a violation of the provision if the home inspector is compensated by or compensates the broker in a profit-sharing arrangement. Even the offer of such an arrangement could constitute a regulatory violation. A home inspector must avoid conflicts of interest with a client or an owner of property that is subject to an inspection by the home inspector. A client’s interest in knowing all defects of a property, which could potentially hinder a deal, transaction, or commission, conflicts with a realtor who employs or is associated with the home inspector because they are a related business or affiliated with the same corporate entity.
The Commission has the authority to proceed with regulatory action based on a consumer complaint or a complaint that it initiates, refer the matter for criminal prosecution, or both, pursuant to Md. Ann. Code, Bus. Occ. & Prof. §§ 16-601 and 16-706(a), including a violation of the provisions set forth in §§ 16-701.1 and regulations applicable to home inspectors, COMAR 09.36.Walk & Talk Consultations
Based on information from those in the real estate industry, the practice of a "walk-and-talk" type consultation or survey have become more commonplace because of the competitive real estate market together with the need to implement protective and restrictive access to available properties due to the continuing COVID pandemic. The Maryland Commission of Real Estate Appraisers, Appraisal Management Companies, and Home Inspectors ("Commission") has received questions about the validity of these services as they relate to home inspections. The Maryland legislature has established the definition and mandatory content of a home inspection as set forth specifically in §§ 16-101(i) and 16-4A-01, Business Occupations and Professions Article, Annotated Code of Maryland.
At a minimum, a home inspection must: 1) be provided for compensation; 2) be conducted by a licensed home inspector; and 3) contain a written evaluation of readily accessible components. While a home inspection contract can limit the scope of a home inspection, these three conditions, at a minimum, must be satisfied to be considered a home inspection under the applicable laws and regulations.
A home inspection requires a licensed home inspector to be able to adequately inspect components and system conditions as set forth in the Home Inspector Minimum Standards of Practice, COMAR 09.36.07.01-.13, sufficient to result in a written evaluation of such findings, as defined in § 16-101(i), Business Occupations and Professions Article, Annotated Code of Maryland.
If an individual misrepresents a “walk-and-talk” consultation or survey as a valid home inspection, the individual may be subject to regulatory action by the Commission and, if warranted, the imposition of an administrative sanction. While the Commission’s authority over an individual licensed as a home inspector is limited to such individual’s performance of home inspections, or the provision of such services by an individual without the required license, the service described herein should not be called, described, or referred to as a “home inspection” as it does not comply with the definition of a home inspection established under Maryland law.
A home inspector who misrepresents a “walk-and-talk” or any other type of consultation that does not result in a written evaluation as defined in § 16-101(i) and which complies with § 16-4A-01, Business Occupations and Professions Article, Annotated Code of Maryland, to be a valid home inspection may be subject to regulatory action by the Commission.
Effective October 1, 2019, Senate Bill 20 - Appraisal Management Companies - Notice and Response Requirements for Violations - Repeal of Exception, established that an appraisal management company (AMC) must always provide notice to an appraiser and an opportunity for the appraiser to respond when the AMC removes an appraiser from its appraiser panel or otherwise refuses to assign requests for real estate appraisal services.
Read the new law.
Proposed Regulations Currently Open for Public Comment
None at this time.
Contact the Commission
Maryland Real Estate Appraisers, Appraisal Management Companies and Home Inspectors
1100 N Eutaw St. 5th floor
Baltimore, MD 21201
410-230-6363 Fax: 410-333-6314