IRS and Appraisal Oversight Rules Paused for Assessment

In this issue:
- Trump Executive Order: A January 20 executive order pauses new and pending regulations for review.
- IRS Oversight: Proposed IRS and appraisal oversight rules face likely delays.
- New Webinar: The effects of the appraisal lexicon.
Insights
Trump Executive Orders to Pause Appraisal Rules
On January 20, 2025, President Trump issued an executive order instituting a regulatory freeze pending review. This order directs all executive departments and agencies to halt the issuance of new regulations and to withdraw or postpone pending regulations until they undergo review by the new administration.
At least two proposed rules relating to appraisal regulations will likely be impacted by the Executive Order. The IRS has proposed updates to the regulations governing practice before the agency, commonly known as Circular 230. These proposed changes aim to:
- Remove or update provisions related to registered tax return preparers and tax return preparation.
- Clarify that the Office of Professional Responsibility retains jurisdiction over practitioners who have been suspended or disbarred from practice.
The proposed regulations could significantly affect appraisers by allowing the IRS to address misconduct even in cases where no penalty has been assessed. Under the proposal, appraisers would statutorily be required to conform to USPAP or the International Valuation Standards (IVS) in administrative proceedings.
The Federal Financial Institutions Examination Council has proposed a rule titled “Enforcement Authority Regarding the Effectiveness of State Appraiser and Appraisal Management Company Regulatory Programs.” This proposed rule aims to establish a framework for the Appraisal Subcommittee’s enforcement authority over state appraiser regulatory agencies, ensuring they maintain effective programs for overseeing appraisers and Appraisal Management Companies (AMCs).
The freeze mandates that agencies refrain from advancing new or pending regulations until they are reviewed and approved by the incoming administration. This review process ensures that the proposed regulations align with the current administration’s policy objectives.
Therefore, the IRS’s proposed updates to Circular 230 and the Appraisal Subcommittee’s proposed rule on state appraisal board oversight will probably be delayed as they undergo this review. The timeline for finalizing and implementing these changes will depend on the outcomes of the administration’s assessment and any subsequent directives.
Another area where Trump's actions affect appraisal is with the Property Appraisal and Valuation Equity (PAVE) Task Force. The underlying executive order establishing the PAVE Task Force was also rescinded by President Trump. The PAVE Task Force website and corresponding information have been disabled.
Click here for a full rundown of the real estate related Executive Orders taken by President Trump.
2025 Membership Renewals
When you pay your Appraisal Institute membership renewal in full by January 31, 2025, you will receive a discount code for one free seven-hour online (on-demand) Appraisal Institute course (excluding USPAP).
The discount code will be sent via email and is valid until December 31, 2025.
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- Log in to your Appraisal Institute account
- Click on the green button: Click Here to Renew Your Membership
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Trending Topics Thursdays: Sign up for our next free webinar
The Lexicon of Appraisal: When common terms take on multiple roles
February 6, 2025, 12-1 pm ET
Terms like “market value,” “market rent,” and “fee simple” have nuanced definitions, and the appropriate usage of the term may be dependent on the specifics of your assignment. Our appraisal and litigation experts will help you explore your options and discuss how you can decide on the appropriate information to include in your report.
Our panelists will discuss:
- The meanings of terms such as "market value," "fair market value," “market rent," and "fee simple"
- How these meanings can be dependent on assignment context
- Potential ways of understanding and using these terms in various contexts
- Tips for thinking critically about your usage of such terms
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Our Community
A Message from Kelli Kline Mayhew, MAI, SRA and the AIERF
What is Appraisal Institute Education and Relief Foundation (AIERF)? Most Appraisal Institute members have heard of it. Yet, few know the breadth of its influence since its inception in 2018, and the profound impact it has had on our members since. What we do touches the lives and careers of every single member of our organization every single year, as well as the entire appraisal profession. The AIERF board is tasked with tremendous responsibility, and I have found my time in service to the board to be an honor and a labor of love. We have the pleasure of helping people pursue their dreams and celebrate their achievements, and the opportunity to help them pick up the pieces when life throws them a curveball. I know something about life’s curveballs, and just how useful AIERF can be when a little help is needed. Hurricane Helene recently devastated my North Carolina community. What I learned is that you can never be fully prepared for a natural disaster, and having a resource available that can offer immediate assistance is critical. I’d like to introduce you to the outstanding work AIERF does and how it can help YOU.
The mission of the Appraisal Institute Education and Relief Foundation (AIERF) is simple. We support and advance the appraisal profession. We do that through scholarships for aspiring appraisers, support of the Lum Library, awards for practitioners pursuing excellence in the field, and emergency relief for appraisers who have experienced financial, physical, or emotional hardship.
AIERF is the platform through which these specific missions are now served, and in the intervening years, the combined outreach has been transformative for the appraisal profession. Every year, tens of thousands of dollars are awarded as college scholarships, AI course scholarships and PAREA scholarships. We are tasked with investing in the future of our profession, and we pursue that mission with voracious intent. In 2024 alone, there were 76 scholarships awarded in 2024, just shy of $120,000 and served dozens of individuals. And we are committed to uplifting our colleagues whenever and wherever need arises. Since 2005, more than $440,500 in emergency financial assistance has been provided to appraisers and other individuals in need.
For the members of the Board of Directors, our service is more than executing the mission of a charitable organization. We recognize that we are serving our colleagues and friends and our profession, and we do it with immense gratitude and pride. Our efforts would not be possible without the financial support of Appraisal Institute members through donations and other contributions. If you would like to support the outreach of AIERF you can do so in two ways. You can use the link below to make a donation online.
Donate - Appraisal Institute Education Relief Foundation (aierf.org)
Or, if you would like to send a donation via regular mail, please send to:
Appraisal Institute Education and Relief Foundation
c/o Appraisal Institute
200 W Madison St., Suite 2000
Chicago, IL 60606
NOTE: Please make check donations payable to “The Appraisal Institute Education & Relief Foundation”
AIERF is organized as a charitable, literary, educational, and scientific Section 501(c)(3) non-profit. Your donations are tax deductible. Your donation is a investment in this profession – for the present and the future. We appreciate your generosity.
Until next week,
Team Appraisal Institute