TL;DR
A Florida real estate licensee may value property for a client WITHOUT holding an appraiser license, but may never call the result an appraisal. The controlling provision is §475.612(3), which states that the appraiser-licensing requirement does NOT APPLY to a real estate broker or sales associate who, in the ordinary course of business, performs a COMPARATIVE MARKET ANALYSIS (CMA), gives a PRICE OPINION, or gives an opinion of the value of real estate — HOWEVER, IN NO EVENT MAY that comparative market analysis, price opinion, or opinion of value BE REFERRED TO OR CONSTRUED AS AN APPRAISAL. Section 475.612(2) reinforces the point: a licensee who is not a certified or licensed appraiser may provide valuation services for compensation so long as they do not represent themselves as certified, licensed, or registered as an appraiser. So the line is not about WHETHER a licensee may estimate value — they clearly may, and may be paid for it — but about the LABEL and the credentials claimed. Calling a CMA or broker price opinion (BPO) an "appraisal," or holding oneself out as an appraiser without the credential, is a violation that can draw discipline under Chapter 475. An actual APPRAISAL, and use of the protected titles "certified real estate appraiser," "licensed real estate appraiser," or "registered trainee real estate appraiser," require certification, licensure, or registration under Part II of Chapter 475. The distinction matters most in lending: federally related transactions generally require a licensed or certified appraiser's appraisal, which a CMA or BPO cannot substitute for.
Two different work products
The subject turns on keeping two work products distinct. A CMA (comparative market analysis) or BPO (broker price opinion) is an estimate of value or of likely sale price that a real estate licensee prepares, typically by analyzing comparable sales and market conditions. An APPRAISAL is a formal, independent opinion of value produced by a state-certified, state-licensed, or registered trainee appraiser in accordance with professional appraisal standards.
Florida law lets licensees perform the first without becoming the second, but polices the boundary strictly. The reason is consumer protection: an "appraisal" carries a professional and regulatory weight — independence, standardized methodology, and a licensed author accountable under appraisal law — that a market-driven CMA does not. Letting a CMA be labeled an appraisal would let that weight be borrowed without the credential behind it. For the discipline that attaches to holding oneself out beyond one's license, see our guide to license law and conduct rules.
What §475.612 actually permits
Part II of Chapter 475 governs appraisers, and §475.612 sets the certification, licensure, or registration requirement. Its subsections carve out exactly what a non-appraiser licensee may do.
The title and report restriction — §475.612(1). A person may not use the title "certified real estate appraiser," "licensed real estate appraiser," or "registered trainee real estate appraiser," or any abbreviation or words to that effect, or ISSUE AN APPRAISAL REPORT, unless certified, licensed, or registered under Part II.
Valuation services are still allowed — §475.612(2). The section does not preclude a Florida licensed real estate broker, sales associate, or broker associate who is not a certified or licensed appraiser from PROVIDING VALUATION SERVICES FOR COMPENSATION, so long as they do not represent themselves as certified, licensed, or registered under Part II.
The CMA carve-out — §475.612(3). The section does not apply to a real estate broker or sales associate who, in the ordinary course of business, performs a comparative market analysis, gives a price opinion, or gives an opinion of the value of real estate. HOWEVER, in no event may that comparative market analysis, price opinion, or opinion of value be REFERRED TO OR CONSTRUED AS AN APPRAISAL.
Read together, these subsections draw a clean line. A licensee may estimate value, may be paid to do it, and may do it routinely — what they may not do is issue an appraisal report, claim an appraiser title, or let their estimate be called an appraisal.
The rule in one sentence
The heart of the exam point is a single clause worth memorizing in substance, and confirmed in the statutory text: a licensee's CMA, price opinion, or opinion of value MAY IN NO EVENT be referred to or construed as an appraisal. Everything else follows from it.
That means a licensee can prepare a CMA to help a seller set a listing price, can prepare a BPO for a lender or asset manager evaluating a property, and can charge for the work — but the document must not be titled or described as an appraisal, and the licensee must not sign it as an appraiser or imply appraiser credentials. The prohibition is on the CHARACTERIZATION, not on the activity.
| Activity | Non-appraiser licensee may do it? | Authority |
|---|
| Perform a CMA in the ordinary course of business | YES | §475.612(3) |
| Give a price opinion / BPO | YES | §475.612(3) |
| Be compensated for valuation services | YES | §475.612(2) |
| Call the CMA/BPO an "appraisal" | NO | §475.612(3) |
| Use an appraiser title or issue an appraisal report | NO | §475.612(1) |
Why the line matters in lending
The distinction has real teeth in the mortgage context. Federally related residential transactions generally require an APPRAISAL performed by a state-licensed or state-certified appraiser, and a CMA or BPO cannot satisfy that requirement no matter how careful it is. A licensee who supplies a BPO to a lender for a purpose that legally requires an appraisal, or who lets the BPO be treated as one, creates exposure for everyone involved.
Florida law does recognize a narrow, separate concept — an EVALUATION — that an appraiser may perform in connection with certain federally regulated real estate financial transactions, subject to the standards imposed by the federal financial institutions regulatory agency; but §475.612 is explicit that even an evaluation may not be referred to or construed as an appraisal. The consistent theme across every subsection is that the word "appraisal" is reserved. For how valuation interacts with the disclosures a seller must make, see our guide to seller property disclosure requirements.
Practical guidance for licensees
The compliance rules are simple to state and easy to violate under time pressure. Title the document a "Comparative Market Analysis" or "Broker Price Opinion," never an "appraisal." Do not use appraiser titles or designations unless actually held. Do not issue anything styled as an appraisal report. When a client or lender needs an appraisal — as in most purchase-money mortgage lending — refer them to a licensed or certified appraiser rather than trying to stretch a CMA to fit.
The underlying professional-standards framework for appraisers, including the standards an appraiser must follow, sits elsewhere in Part II of Chapter 475 and in board rule; a non-appraiser licensee does not need to satisfy those standards precisely because their work product is not an appraisal. That is the trade-off the statute strikes: freedom to estimate value without appraiser obligations, in exchange for never claiming the appraisal label. For the licensing structure that administers both regimes, see our guide to the FREC and DBPR licensing structure.
Frequently Asked Questions
- Can a Florida real estate agent perform a CMA without an appraiser license?
- Yes. Under §475.612(3), the appraiser-licensing requirement does not apply to a real estate broker or sales associate who, in the ordinary course of business, performs a comparative market analysis, gives a price opinion, or gives an opinion of the value of real estate. The licensee may do this routinely and may be compensated for valuation services under §475.612(2). The one hard limit is that the CMA, price opinion, or opinion of value may in no event be referred to or construed as an appraisal.
- What is the difference between a CMA and an appraisal?
- A CMA (or BPO) is a real estate licensee's estimate of value or likely sale price, typically based on comparable sales and market conditions. An appraisal is a formal, independent opinion of value produced by a state-certified, state-licensed, or registered trainee appraiser under professional appraisal standards. Florida law lets licensees prepare CMAs and BPOs but reserves the word "appraisal" and the appraiser titles for credentialed appraisers, and it prohibits a CMA from being referred to or construed as an appraisal.
- Can a licensee be paid for a broker price opinion?
- Yes. Section 475.612(2) provides that the section does not preclude a Florida licensed broker, sales associate, or broker associate who is not a certified or licensed appraiser from providing valuation services for compensation, so long as they do not represent themselves as certified, licensed, or registered as an appraiser. The compensation is not the problem; claiming appraiser credentials or calling the product an appraisal is.
- Can a CMA or BPO be used instead of an appraisal for a mortgage?
- Generally no. Federally related residential mortgage transactions typically require an appraisal by a state-licensed or state-certified appraiser, and a CMA or BPO cannot substitute for it. A licensee who supplies a BPO for a purpose that legally requires an appraisal, or allows it to be treated as one, creates regulatory exposure. When an appraisal is required, the correct step is to refer the client to a licensed or certified appraiser.
- What titles require an appraiser credential?
- Under §475.612(1), a person may not use the title "certified real estate appraiser," "licensed real estate appraiser," or "registered trainee real estate appraiser" — or any abbreviation or words to that effect — or issue an appraisal report, unless certified, licensed, or registered under Part II of Chapter 475. Using any of these titles, or issuing something styled as an appraisal report, without the credential is a violation.
- What happens if a licensee calls a CMA an appraisal?
- It is a violation of §475.612 and can draw disciplinary action against the license under Chapter 475. The prohibition is on the characterization: the licensee may perform and be paid for the underlying valuation, but describing or construing it as an appraisal, or signing it in a way that implies appraiser credentials, crosses the line the statute draws. The safe practice is to title the work a CMA or BPO and refer clients to a licensed appraiser when an appraisal is actually required.
Bottom Line
Florida lets a real estate licensee value property without an appraiser license, but reserves the word "appraisal." Under §475.612(3), the appraiser-licensing requirement does NOT apply to a broker or sales associate who, in the ordinary course of business, performs a COMPARATIVE MARKET ANALYSIS, gives a PRICE OPINION, or gives an opinion of value — but in NO EVENT may that work be REFERRED TO OR CONSTRUED AS AN APPRAISAL. Section 475.612(2) confirms a non-appraiser licensee may provide valuation services FOR COMPENSATION so long as they do not represent themselves as a certified, licensed, or registered appraiser, and §475.612(1) reserves the appraiser titles and the issuance of an appraisal report to those credentialed under Part II of Chapter 475. The prohibition is on the LABEL and the credentials claimed, not on the activity: a licensee may prepare and charge for a CMA or BPO, but must title it accurately, must not claim appraiser status, and must refer clients to a licensed or certified appraiser when a true appraisal is required — as it generally is in federally related mortgage lending, where a CMA or BPO cannot substitute. For related topics, see our guides to license law and conduct rules, seller property disclosure requirements, and the FREC and DBPR licensing structure.
Source: Fla. Stat. §475.612 — Certification, Licensure, or Registration Required (full text) · Fla. Stat. §475.612 — annotated text and subsections · Florida Realtors — Appraisal, CMA, and BPO rules for licensees