Your Voice Matters: Feedback for TDLR's Property Tax Professionals Program

In March 2014, TDLR asked licensees and the public to share their ideas and experiences related to TDLR. People participated through face-to-face meetings around the state, on an online crowdsourcing website, through social media, and by email.

Participants were asked to answer four questions:

• What does TDLR do well?
• What can TDLR do better?
• What changes would you make to TDLR if you were king or queen for a day?
• Over the next five years, what major changes will affect the way you do business and the services we provide?

We used people’s responses to help us create our strategic plan.

Below you will find participants’ responses concerning TDLR’s Property Tax Professionals program.

What does TDLR do well?

• TDLR set up website so that there is a two year look back when it was requested.
• The PTP testing program has been much improved in the past few years.
• The TDLR was helpful to me in evaluating and transferring credits from education received through the IAAO prior to moving to Texas.
• When we were first covered under TDLR it may have taken 2 weeks to get an issue resolved, but now I can generally get a correct answer the same day. TDLR was making us have exceptional customer service and they didn't even have it, but now we both can communicate well together.
• Allowing for local test sites has been a cost savings for our office.
• I appreciated the consideration I received when I first applied to get my Level 1 Appraisal License. Like many people, I had some unfortunate circumstances in my past albeit mostly of my own doing, but nevertheless all of the information was considered and I was granted my license and an opportunity to begin again.

What can TDLR do better?

• Different and inconsistent answers (Cust. Srvc) (PTP/SCP)
• Can’t register all registrants at end of year (PTP)
• Certificate and cards come at 2 different times (PTP)
• Could you add a field to the ImagineTDLR website to distinguish comments by the relevant profession? It would be helpful if there was an area for PTP (or electricians, or beauticians, etc.) to go to directly to see comments filed by others in our specific field.
• Instead of renewing each year and looking back over 2 yrs. for CPE, just change the renewal process to every two years with a minimum of 30 hrs. CPE that includes USPAP update, laws, ethics and rules update. This in my opinion would make the process simpler and easier to follow. The TALCB does this for State Certified Appraisers. Thanks
• It is very difficult to get through to anyone with any knowledge or authority concerning the PTP program. And even when my messages do penetrate through the bureaucracy to the appropriate party I do not get the courtesy of a response by phone or email. Ever. It would be a vast improvement if TDLR provided accessible, knowledgeable, empowered, & courteous customer service staff specific to our area of concern.
• We have several colleges nearby. Courses that they offer should be accepted for CE units. I do not mean just anything but related fields. I work in a 4 person appraisal district. We need to make our spending cover as much as possible. It is required that I take a Public Funds Investment Training. These hours should count toward CE. We shouldn't be limited to just appraisal or collection as this world is made up of so much more information that we need to do our jobs professionally and accurately.
• I believe the renewal date should be every two years and parallel the recertification date. This would save TDLR money by not having to print the credit card type license every year and would also make it easier for the appraisers to keep up with.
• There are numerous RPA's that are state certified appraisers and must complete 28 hours of CEU's every two years. It would be cost and time effective if TDLR would recognize the national educational providers that TALCB has approved and allow those CEU's taken for state recertification to count towards the RPA recertification. I recently completed two online courses in architectural history and building "green" which greatly enhances my role as an RPA.

What changes would you make to TDLR if you were king or queen for a day?

• Allow PTP renewal process to take place all at one time and align CE requirement at the same time (the cookie cutter doesn’t fit here)
• Annual CE requirement tied to end of calendar year
• Continuing ed requirements for PTP renewals – look at an eye toward number of hours and buckets required
• Do away with CE buckets!
• End of April to end of August can’t provide CE (because of hearings)
• Provide extension or waiver for CE requirement
• Sync webpage up with license expiration information – the info we are publishing that people who have timely filed are clearing RFI’s
• The CS division should have SMEs for the PTP
• Before you were handling our education it was much simpler. The printouts we were sent showed the courses we had taken and the courses we needed to take. If we had questions, we could call and get the answer. Now it is just one run around after another. I think changing it to TDLR was a huge mistake. Sounds like government at work.
• Every year I need 30 CEU's to renew my license. Our software company occasionally does webinars but we only earn 1 CEU. Out of town classes are very expensive and can average $800.00 per person when you consider hotel, meals, transportation and the class itself. There are no classes nearby that could be done in a day. One solution would be either extend the number of years before renewal is needed and/or lower the number of CEU's needed. It becomes very stressful trying to earn the credits without spending a lot of money. Would it be possible for TDLR to put on webinars where a group could participate or offer renewal (day) classes in more cities. Thank you.
• I agree that Ethics and USPAP are very important in our profession. Having to take a course in both every year, redundant. They do not change and you or either going to be a professional or not. There are other issues that would be better to cover than these to help in our every day work processes.
• I would improve the level of communication provided between profession-specific TDLR representatives and the professionals being regulated by the organization.
• Licensing renewal every two years that includes 30 hrs. CPE and includes USPAP update, ethics, laws and rules update. This would be easier to follow than looking back over a two year period.
• Tax representatives select properties that are not truly comparable resulting in substantial reductions in tax value, (causing this property now to be lower than it's true competitive set) this actually creates inequality, the very thing this section of the tax code was created to do, thus millions of lost revenue for the state. This appears to be something that is becoming more and more prevalent as tax representatives discover that this is the most effective way to receive the deepest discounts.
• The RPA and TALCB certified general and residential licenses are BOTH Texas appraiser licenses. TDLR acts like the TALCB is a step child. The education classes are the same subjects and TALCB classes can be taken online. If you hold both licenses, why should you have to take 2 different USPAP classes. Its the same thing. Not to mention the time and money saved having to travel to take classes. Now I believe you should have to sit in classes to get the license, but not for continuing education. The teachers class stated there is nothing worse to have in your class than a bored RPA. Combine the education.
• There are many RPA's who are also licensed as state certified fee appraisers which adds further credentials to the mass appraisal industry. State certified fee appraisers are required to complete 28 CEU's every two years, TDLR should recognize and accept any national educational providers and allow these CEU's to count towards the RPA recertification process. This could potentially cut costs for the CAD's across the state as well as reduce the time out of the office for having to complete two separate sets of CEU's.

Over the next five years, what major changes will affect the way you do business and the services we provide?

• Increase in TX population (increase in #appraisers)
• Retirements in PTP industry
• At the rate it is going, we will not be able to do the job for having to comply with all the laws, rules and regulation we are facing. We are so consumed with the fear of not meeting the CE requirements, interpreting the law correctly or not complying to a regulation properly, we get preoccupied and lose focus on our goal. Another item is we don't see a lot of younger people entering this business and the rest are getting ready to retire so not sure where that leaves this industry.
• I think increased legislative intervention will create increased pressure for appraisal districts to come up with the "right" number in valuations before the ARB hearings - the value that is high enough to satisfy the taxing entities yet low enough to avoid taxpayer appeals - which may or may not represent the actual market value of the property.
• I was/am a licensed Commercial Fee Appraiser by the TALCB and have been for 15+ years, practicing valuation, consulting and asset management. I completely understand the need for some additional education in transitioning to the appraisal district as a commercial appraiser. For example, mass appraisal and tax law. What I'd like to see is some sort of acknowledgement or consideration for being educated and experienced in a greater capacity in the past. To be an appraiser at an appraisal district we have to obtain an RPA through the TDLR. Would the TDLR ever consider the TALCB license (commercial for commercial and residential for residential) to be sufficient and not require a RPA license to be obtained?
• Our counter traffic may slow down. No new ideas.
• It appears our Legislators are attempting to create a "one size fits all" methodology for CAD's. Due to the diversity of our great state, I do not believe this is a possibility and each CAD should be based on its own performance and not be punished for the poor performance of other CAD's. Those CAD's that do not have the budget to implement the government mandates should receive state funds for the needed resources so the costs are not passed thru to the taxpayers of those counties.

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