J-Barroom Brawl

When Cecilia Gardner, general counsel and executive director of the Jewelers Vigilance Committee, requested a grant from the JCK Industry Fund in October of 2000, she proposed "that JVC undertake to create a 'bar association' (we propose the name The Jewelers Board of Appraisal Review, or 'J-BAR') for appraisers which would act as a central clearinghouse for qualified appraisers, provide a central forum for debating issues in the appraisal field, and be a venue for the settlement of disputes regarding appraisal activity."

The organization's primary goal was to ensure that all jewelers who perform appraisals had at least a minimum level of appraisal skill and knowledge. Another goal was to bring the diverse group of appraisal associations together under the JVC umbrella, which Gardner said would "benefit all who are impacted by appraisal activity—jewelers, insurance companies, lawyers, and the consuming public."

Since the proposal was made, Gardner has released an appraisal course (titled "Jewelry Appraisal Basics") and published a directory of those who have successfully completed the course.

But while the original J-BAR concept was lauded, its execution has been widely panned. Both the course content and the directory of beginning appraisers have unleashed a firestorm of criticism from many professional jewelry appraisers and associations, some of which have labeled the course inadequate, improper, and unethical.

Are the criticisms valid, or is this just another example of appraisal politics as usual?

A course, of course. "It wasn't supposed to be an appraisal course," says Charles Ellias, a Certified Appraiser of Personal Property (CAPP) with the International Society of Appraisers (ISA), now with Costello Jewelry Company in Glen Ellyn, Ill. "Cecilia told us, 'Our goal is not to teach appraising.' But yet they're teaching a course."

Gardner acknowledges that "Jewelry Appraisal Basics" is a course but describes it as "a very basic starting-out course for people who have absolutely no education in appraising. It's a first step. And it's based on legal compliance with FTC guidelines and other laws."

Nancy Stacy, a Master Gemologist Appraiser (MGA) with the American Society of Appraisers (ASA) and a vice president on the ASA Board of Examiners, has another take on the course controversy. Stacy, who served six years as ASA's Gem & Jewelry Education chair, doesn't object to "a course that is introductory in nature," but she believes the J-BAR course is not consistent with appraisal theory and contains "information that will have to be un-learned in the context of further appraisal training."

Stacy isn't alone. Mona Miller-Smith, MGA with the ASA, a National Gem & Jewelry Appraiser (NGJA) with the National Association of Jewelry Appraisers (NAJA), and the owner of Pacific Gem Lab in Portland, Ore., is ASA's director of education for the gems and jewelry division and a former member of the board of ASA governors. She says J-BAR is "contradictory to what I'm teaching. And we're not just being too picky." Miller-Smith says that ASA officially supported the J-BAR mission statement, but now she has to do an about-face and not support the course.

"ASA's gems and jewelry discipline committee and its board of governors both formally endorsed the J-BAR mission and objective statements with my encouragement and support," says Larry Phillips, ASA's incoming international president. Phillips is a former chair of the ASA gems and jewelry discipline committee as well as a course developer and instructor. "They did not endorse the J-BAR course, and it is highly unlikely that they will do so. J-BAR failed miserably to develop even an elementary insurance appraisal education for retail jewelers."

"It's going to have to be completely rewritten," says Miller-Smith. She believes the course should not only make the necessary corrections but also add some elements, including a definition of "exactly what they'll be qualified for when they finish the course." She also objects to including the names of J-BAR graduates in a book with others who are more qualified. "You're not teaching them how to appraise," she says. "You're telling them what is good and bad, but not how!"

In the beginning. According to the JVC Web site, "based on the number of complaints centered on incompetent or fraudulent appraisals, JVC decided it was time to take action."

Gardner has pointed out that thousands of retail jewelers—many with no appraisal training—perform appraisals every day. She writes, "The cornerstone of this new movement was the idea of an appraisal course setting out the basics of appraising while highlighting the pitfalls."

J-BAR's "Jewelry Appraisal Basics" was "founded on the fundamental principles of jewelry appraisals," Gardner continues. "The course discusses legal liabilities associated with appraising jewelry, types of appraisals, methods of valuation, elements of an appraisal, language to include on appraisals, and a thorough discussion of sound business ethics as applied to jewelry appraisals. This basic education provides a starting point from which jewelry professionals can build towards more technical education."

Some professional appraisers do support the course. John Abbott, Graduate Gemologist, MGA with ASA, and an expert in rare coins as well as jewelry appraising, says J-BAR was never supposed to be the "be-all and end-all" of appraisal certifications. "J-BAR is a wonderful first step," he says. "Right now it's the Wild West out there. Anybody who can pick up a pencil is out there doing appraisals."

Abbott believes strongly in education but says the high cost may leave most retail jewelers out of the loop. "I'm gung-ho ASA, but ASA is cost prohibitive to go through the courses."

Abbott believes J-BAR has filled the gap for the thousands of jewelers who write appraisals with no formal appraisal training. "I think that if somebody who's in the trade reads the J-BAR and practices using it, they're going to be doing so much better than 90% to 95% of the reports that I see on a regular basis," he says. "A lot of appraisals are done by people who have no gemological training or valuation training."

Susan Eisen, MGA, Certified Gemologist Appraiser (CGA) with the American Gem Society (AGS), is a retail jeweler in El Paso, Texas, who has been credentialed with three appraisal organizations (ISA, ASA, and AGS). She believes the criticisms of the J-BAR course are "unfounded" and says it will "show the people that are taking J-BAR that, 'Hey, this is serious business. Maybe I shouldn't be doing these appraisals,' which is one of the reasons J-BAR did this to begin with." Eisen believes J-BAR will encourage people who are interested in appraising to take additional courses.

"I am in favor of the mission of J-BAR, and that it deals with appraisals from a legal background and standpoint, as opposed to an appraisal standpoint," Eisen adds. "And that's why I think it's needed for the industry."

Devil in the details? Numerous professional appraisers fault J-BAR's details and believe the course conflicts with what is taught by the major appraisal organizations. They say the course's definitions and methodology are confusing, inconsistent, and improper. They also claim the course promotes unethical practices.

Says Stacy, "My highest expectation for the course, and biggest disillusionment with it, is in the area of appraising for insurance coverage. Most appraisals jewelers write are for insurance coverage on items sold by the store. If nothing else, Appraisal Basics should have gotten that part right. Instead, the methodology is jumbled, terms are incorrectly used, and some of the information is simply wrong."

William Hoefer is a paralegal, a course writer, a teacher for ISA's "Expert Witness" course, author of the "Advanced Personal Property Appraisal" (APPA) course of the Jewelers Educational Foundation (JEF/AGS), Webmaster and editor for Appraiserunderoath.com, and owner of Hoefer's Gemological Services in Tampa, Fla. His complaints about J-BAR concern the two valuation methods that the course defines as standard: the Price/Cost Method and the Market Data Method. These methods are critical factors in appraising, the purpose of which is to ascertain the correct value of a piece of jewelry so it can be insured for that value.

Consider this from J-BAR: "The cost method adds up the parts and labor and then applies the markup in the area where the item is sold." Hoefer notes that value is most often based on the area in which an item will be replaced, and not where it was purchased.

Cos Altobelli, CGA with the AGS, is the author of two appraisal books and the founder and first chair of the Council of Jewelry Appraisal Organizations (CJAO), representing AGS, NAJA, and ISA. According to Altobelli, in some instances, an appraisal can be even more complicated.

"You obtain information about the piece from the client," he says. "Can this piece be replaced from wherever, or do you have to go back to Buccellati [for example] to get a replacement? If it's something copyrightable, something registered, then this has to be the way it's resolved." And most importantly, this must be written into the appraisal. "You really need to know all of the ingredients beyond the scripted material," says Altobelli.

But Eisen points out that every course contains controversial material. "In fact, there are things that ISA says that ASA doesn't subscribe to," she says. "I understand there are inconsistencies. There are things that ASA subscribes to that AGS doesn't subscribe to. So theoretically, there are differences among all three of the appraisal organizations I belong to."

Define 'this.' "The J-BAR course is so fundamentally flawed that even its definition of an insurance appraisal is seriously wanting," says Hoefer, citing the course's definition of "insurance replacement," which includes "… or to satisfy their curiosity."

"What does writing an appraisal 'to satisfy curiosity' mean?" he asks. "It is a completely nebulous comment. A proper appraisal starts by precisely defining and limiting its use. 'Curiosity' does just the opposite."

But Don Palmieri, Graduate Gemologist, MGA with the ASA, owner of the Gemological Appraisal Association, publisher of the gem pricing guide Palmieri's Market Monitor, owner of the Gem Certification & Appraisal Lab, and owner of the Diamond Profile Laboratory in New York City, says J-BAR's citing curiosity as one of the primary uses of an Insurance Replacement Appraisal is proper. "Lots of people come to me for appraisals because they're curious about the value.… Often they really want to know they got what they paid for and didn't get ripped off. I'm sure that less than half of them go to the trouble to schedule a piece of jewelry. Most people are curious."

Hoefer quickly points out that one can be curious about what it cost, or what it will sell for, or what it should be insured for, all of which could be different values. Hoefer cites another, more troubling concern—"conflict of interest," also known as "interfering with a sale." According to J-BAR, if the appraiser did not sell the item in question, he or she should note on the appraisal that "you regularly buy and sell this type of item and could provide a replacement for it in the event of a loss." In essence, the appraiser tells the client he can sell them the item, and that they need not return to the place of purchase.

But even the experts can't agree on this point. Phillips says this comment is recommended by the 1995 JVC Appraisal Task Force Guidelines. And Palmieri says such a statement is appropriate as long as all information is unambiguously provided to the client.

But Altobelli says it's "unethical" and "all wrong."

Gardner sees it differently: "We do not assume that this is an insurance replacement appraisal," she says. "It could be for any number of appraisal reasons."

Gardner uses the following hypothetical appraisal as an example: "Some jeweler writes an appraisal and the piece is already gone. It's been lost or stolen, and so they go to the local guy who submits the appraisal to the insurance company. If you're a jeweler and writing an appraisal, you need to disclose that you could replace the item if you were asked to do so, but did not. Jewelers have been accused of skewing the value because they wanted to replace it. If you might be in a position where you might be challenged because of personal interest, you need to disclose this fact."

"Now she's made this into a casualty loss appraisal, not an appraisal for obtaining insurance replacement," Hoefer responds. "Nowhere in the course did it present casualty loss assignment theory, which requires a different date of value and value definitions."

Hoefer points out that "casualty loss" does not use retail replacement value. "Depending on the policy, the insurer will either pay the amount covered (agreed value policies) or the actual cash value (which is defined differently in different states). There are other options, such as partial losses as opposed to a full loss, repair and actual replacement options, etc. This is a complicated area," says Hoefer, who faults J-BAR for not covering such details if casualty loss is to be taught in the course.

Also at issue is J-BAR's appraisal model, which advises appraisers to state: "I certify that, to the best of my knowledge and belief, the statements in this document are true and correct including representations of quality and quantity." Hoefer says diamond grading is opinion, but the statement above indicates that an appraiser has certified a diamond's quality grade. "Never certify something that's just an opinion," he warns.

"Appraisals are statements based on specialized knowledge," says Gardner. "Appraisers should take responsibility for what they are saying." According to Gardner, it's proper to certify a diamond's clarity and color grade since the appraiser also will make a qualifying statement that "diamond grading is subjective." The phrase "to the best of my knowledge and belief …" is the legal standard that applies, she says.

Altobelli disagrees. Certifying the diamond grading opinion, he says, creates an expressed warranty. "It's no longer an opinion," Altobelli insists, and a jeweler could be held liable if the diamond were graded differently by another authority—GIA, for example. This holds the appraiser to a higher standard than GIA itself. After all, GIA doesn't certify diamond grades; it provides only the laboratory's opinion. What's more, says Altobelli, advising a jeweler/appraiser to certify the grade could come back to haunt Gardner: "She could get sued by appraisers for telling them to do the wrong thing!"

"The J-BAR course is often contradictory," Hoefer says. "For example, on page 7, it says, 'The value on the appraisal should be verifiable if necessary. This is not necessarily the price at which the item was sold.' But on page 22 it states, 'Make sure, however, that your selling price is the appraised value for purposes of the appraisal.' Which is it?"

Hoefer also cites J-BAR's definition of the Market Data Method, which states that it "determines the value by using market research and actual prices for buying and selling."

"The Market Data approach is based on actual market activity," says Hoefer. "Unless you assume that this course is specifically designed for retail jewelers to appraise only the items they sell that day, Market Data has little to do with what an item is priced at."

Consider this example: If you know XYZ Jewelers always offers a 20% discount for cash or will discount an item during an end-of-the-month sale, then the ticketed price is not valid for an insurance replacement value. "It's like looking at an auction catalog," says Hoefer. "The printed 'sale estimate' is not the true value of such pieces. The value is determined by market activity such as actual sales, not willy-nilly price tags.

"Appraisers determine and report values, not prices," adds Hoefer, who says that the J-BAR course "incorrectly uses 'price' and 'value' as if they were synonymous."

Gardner insists it is correct. "It says 'actual prices for buying and selling.' I think that means the same thing, don't you?"

Hoefer cites another alleged inconsistency: "On page 40, it reads, 'Have a policy not to buy what you appraise.' But in the very next sentence I'm told, 'Then you are free to make an offer to Ms. Jones and to help her find a different appraiser.' So what's the score? Am I an appraiser or a liquidator? Either something's missing, or the course writers don't know what they want to say."

But Eisen says such arguments are really arguments over semantics. "I think the greater issue is that it's very serious business … with serious liability. I think J-BAR's intent was to tell jewelers, in case they don't know, that 'you're treading on very thin ice.' And I think J-BAR's done that."

Reinventing the wheel? There is a lot of contradictory terminology in the context of professional appraisal theory and methods, says Stacy. "The most widely accepted standards for appraisers are set forth in USPAP, the Uniform Standards of Professional Appraisal Practice. While I did not expect the J-BAR course to teach jewelers to write fully compliant USPAP appraisals, I was hoping that at least J-BAR would not conflict with it. Unfortunately, J-BAR invents methods and terminology where it could just as easily have used standard terms laid out in USPAP."

"The J-BAR course violates USPAP mainly through omission of critical requirements, like an effective date," adds Phillips, also a certified USPAP instructor.

But according to Gardner, "USPAP is a standard for personal property, based on a higher standard other than just legal. So I feel the comparison is not relevant here. I certainly don't want J-BAR to be in conflict with USPAP, and I believe it is not in conflict."

And Eisen points out that "even AGS and ASA don't agree on the use of USPAP." Palmieri says such "nitpicking" and "tearing apart of J-BAR's sample appraisal and various portions of the course is not productive."

Having a separate "effective date for an insurance appraisal" for example, isn't necessary, Palmieri says. "Unless it's for an unusual situation, i.e., date of loss, etc., there's no reason to have another date. For what J-BAR is supposed to do, to elevate the insurance replacement appraisal, there are many things that are simply implied here. In this instance, the effective date is implied by the date on the appraisal."

Phillips is unrelenting. "The record-keeping and confidentiality requirements are poorly and inadequately stated. Its graduates are not confined to insurance appraisals or to the items they regularly sell. While it states that a 'gemologist is not an appraiser,' it fails to say exactly what does constitute competency. Many of J-BAR's definitions and concepts are in conflict with those used by USPAP and in professional appraisal practice. For example, 'antique and period' is not a type of appraisal. It might be descriptive of a type of item," says Phillips.

Also at issue is whether JVC followed its own advice in writing the J-BAR course. That advice was given by the 1995 JVC Appraisal Task Force (ATF), which formulated the Minimum Guidelines for retail jewelers on how to write "insurance replacement cost estimate documents." That refers to a type of limited insurance replacement appraisal that's intended solely for new items sold and is "based on the selling prices of a particular establishment, for the intended use of obtaining insurance."

"The J-BAR course flies in the face of virtually every standard established by the original JVC Guidelines," Phillips says. "[The] authors took only a few handy parts and inserted them into J-BAR. They left out the essential ideas and structures that made the Guidelines viable. In addition, the course shows a poor understanding of basic valuation science and an even poorer understanding of USPAP. Why weren't recognized, competent appraisal educators consulted?" he asks.

Yet a sizable portion—possibly 25%—of the J-BAR course came directly from the ATF guidelines, and more than 75% of the ATF recommendations were placed word for word into the new J-BAR course. It's also worth noting that many of those who are objecting to the course today are the same people who wrote the 1995 ATF guidelines.

That was then ... In fairness to the original authors, more than half of the J-BAR course is newly written, and the 1995 ATF recommendations underwent some important edits.

In 1995, for example, ATF recommended that retail jeweler/appraisers not write any other appraisal unless they had formal training. J-BAR relaxes the recommendation by allowing a retail jeweler with little or no training to determine whether he or she is qualified to write an appraisal.

Here's another example. One question asked in both the 1995 ATF recommendations and the new J-BAR is: "Does your customer intend to use the document only for insurance purposes?" Both contain the same response to a "yes" reply: "Include a statement that obtaining insurance is the only valid use of the documentation." In 1995, the recommended response for a "no" reply was: "Preparation of documentation for any other use requires advanced appraisal training outside the scope of these guidelines and should not be attempted without that training." However, in 2004, the answer is: "Question customer to find out what his or her appraisal needs are and determine if you are qualified for that appraisal. If so, proceed. If not, refer them to another appraiser."

"Note the substantial difference," says Phillips. "This is telling the jeweler, 'Go ahead if you think you feel up to it.'" What troubles Phillips and others is that this instruction is going to many retail jeweler/appraisers who don't know—or won't admit—that they have been appraising incorrectly for decades, even on simple insurance replacement appraisals.

Phillips cites another alleged error: "J-BAR asserts that all insurance appraisals are done according to replacement cost new," he says. "This is untrue." In fact, a standard Insurance Replacement Appraisal covers new or used items sold by any establishment, using either a cost approach or market data approach for obtaining a value.

Phillips, Hoefer, Altobelli, Smith, and Stacy say these kinds of errors make the J-BAR course legally and ethically suspect.

But Eisen and Abbott decry such arguments as unconstructive. "I think that we're spinning our wheels in negativity when we could all be working together and building this area of jewelry appraising and making it greater for everybody," says Eisen.

"It's a balancing act," says Abbott. "You can nitpick and find problems with it, but I think it's head and shoulders above anything else that's out there—unless someone really wants to become a professional."

According to Larry Phillips, the following are some of the basic USPAP guidelines under which J-BAR's one-page sample appraisal is found to be noncompliant:

1. Standard 8(2)(b)(i)
   "State the identity of the client and any intended users, by name or type"
   Standard 8(2)(b)(ii)
   "State the intended use of the appraisal"
   "This may seem like a minor problem, but it is not," says Phillips. "The client is certainly adequately identified at the upper right (name, address, etc.), but the intended use is unclear. Therefore, so is the intended user. J-BAR states, 'This appraisal is only to be used for insurance replacement purposes.' Does that mean obtaining insurance or getting indemnified after a loss? I guess we can assume the insurance company is the user, but the intended use should be for 'obtaining insurance.'"
2. Standard 8(2)(b)(iii)
   "Summarize information sufficient to identify the property involved in the appraisal, including physical and economic property characteristics relevant to the assignment"
   "J-BAR's appraisal says the main diamond is 'approximately one carat.' Is it or isn't it?" asks Phillips. "An appraiser also has to state how the value was derived. If it was graded mounted and the weight is estimated (not 'approximated') by volumetric formula, that must be stated (see 8 (2)(b)(viii)). There is insufficient proportion information to set a value on the diamond. There is no mention of condition. There's more I could point out, but this gives you the idea."
3. Standard 8(2)(b)(iv)
   "State the property interest appraised"
   This could be easily handled with the phrase, "assumed to be (or known to be) wholly owned by the client." This is missing entirely from J-BAR, notes Phillips.
4. Standard 8(2)(b)(v)
   "State the purpose of the appraisal, including the type and definition of value and its source."
   Stating the definition of value requires the definition itself, an appropriate reference to the source of the definition, and any comments needed to clearly indicate how the definition is being applied.
   "There is no definition of 'replacement value,'" says Phillips. "There is no statement as to whether the value applies to a new or used item. A new Rolex President and a similar used Rolex President have very different values. There is no anticipated method of replacement, although that's a violation of the JVC Guidelines, not USPAP."
5. Standard 8(2)(b)(vi)
   "State the effective date of the appraisal and the date of the report"
   While one might make the assumption in this case that the date of appraisal is the effective date of the report, USPAP requires a specific statement of the effective date. While the date of inspection is stated by J-BAR (as recommended by the task force guidelines), there is no indication as to who specifically made the inspection. (See 'Certification,' below).
6. Standard 8(2)(b)(vii)
   "Summarize sufficient information to disclose to the client and any intended users of the appraisal the scope of work used to develop the appraisal"
   "The original task force guidelines were 'limited to replacement through the store making the appraisal,'" notes Phillips. "This is of paramount importance. It takes advanced training to consider different markets and market levels. A retailer untrained in valuation science is limited to what he would sell it for or what he would buy it for. He does not have the resources to properly research other markets."
   Phillips adds, "There is no statement of the source of gemological information, (i.e., 'We used our own lab,' 'We used a GTL Report,' or whatever.) What grading system is used? It looks like GIA, but I don't see any statement to that effect.
   "Bear in mind that this is only an incomplete commentary on Standards Rule 8, 'Reporting of a Personal Property Appraisal.' This doesn't include errors and omissions from Standards Rule 7 or violations of the Ethics Rule, the Competency Rule, the Jurisdictional Exception Rule, or the Supplemental Standards Rule, all of which were handled (to one degree or another) appropriately in 1995 by the JVC Guidelines."

Noncompliance with itself? "It's interesting to note that the J-BAR sample appraisal violates its own descriptive standards stated two pages later," says Phillips, who cites the following examples:

Standard: The condition of the item should be described—missing from sample.

Standard: The apparent or known methods of manufacture should be stated—missing from sample.

Standard: Copyrights, patents, and trademarks should be described—unclear on sample.

Standard: Diamonds and colored stones should be graded and described using published systems and nomenclature generally understood by members of the trade and generally accessible to members of the trade and the public. The system used should be stated—sample doesn't say if GIA grading is used or explain the system used.

Standard: As appropriate, gemstones should be described in terms of their shape, color, clarity, cutting quality, measurements, and actual or estimated carat weight—the sample provides insufficient proportioning information, using "approximate" instead of "actual or estimated."

Standard: Gemstones with significant impact on replacement cost should be individually described. A plot or photomicrograph is recommended—sample does not include a plot or photomicrograph.

Is it legally correct? Gardner says of the sample appraisal that if a jeweler can write an appraisal like that, even if Phillips and others are right about its non-compliance, she'll be more than happy. If representing a jeweler in court, Gardner says, "If I have this, I'm golden." And that's the essence of the controversy: While Gardner maintains that J-BAR is "legally correct," appraisers see it as a confused and inconsistent jumble of valuation science.

J-BAR acknowledges that "it will not delve significantly into economic theory, on which much appraising is based," maintaining that valuation science is unnecessary for the beginner to write a good appraisal. But despite Gardner's belief that the jeweler's appraisal would be legally sound, some professional independent appraisers believe that J-BAR appraisers could still be open to a lawsuit.

"After all," asks Hoefer, "isn't a 'good appraisal' one that is both legally correct as well as rendered with sound valuation principles and procedures?"

A final grade? "There are things I like about the course," says Stacy. "It is important for jewelers to know that they take on liabilities when they issue an appraisal, and that an appraisal on an item sold by the jeweler creates an expressed warranty. That is stated very clearly in Basics. There are forthright warnings about writing appraisals with inflated values, but unfortunately no explanation of the harm this does to their clients in wasting money on excess insurance premiums."

"Intentions were good," says Smith. "We all thought, 'This can finally unite all of the appraisal organizations.' The purpose was very good, but the final product is not. Hopefully it can be turned around."

"J-BAR is an important first step in trying to make this profession reasonable and compliant with common sense," says Abbott. "Realistically, what we need to do is at least get a momentum going before somebody else gets a momentum going. I really don't think that we want the people in Washington, D.C., setting up the standards for us. I think that JVC has the ability to see this through. J-BAR is a major first step. Is it where we want to end up? No. But it's a lot better than anything that's been proposed before."

"There's been the same issues brought up in almost every organization that I've been a member of and credentialed in," notes Eisen. "And it's basically an evolutionary process. Like everything else in education, things change, things happen, and it's incumbent upon you, just like you're doing to make us aware about J-BAR, to continue to improve the courses and the compliance to the laws. I'm sure that if there was something illegal in the text, and J-BAR researched it, and confirmed it was illegal, J-BAR would modify their text."

"J-BAR is the only organization I know that can police with some force bad appraisers," says Palmieri. "I want every one of my peers to join because when they screw up, there's an organization that can help wronged consumers, correct the appraisers, or go after them. The first J-BAR is a start. I challenge them to join J-BAR if they engage in providing appraisals."