state appraiser licensing programs were established as a result of fiera to issue credentials and oversee compliance with state laws. some programs are part of an umbrella agency that handles all occupational licensing of the state. they often use pool investigators and assign legal counsel on a per case basis. others are stand-alone agencies that handle appraising and/or real estate. they may have staff investigators and full-time or part-time legal assistants. finally there are states such as north carolina that have an autonomous board set up by state statute. they do not receive state funding and typically hire their own staff. programs that share staff may lack sufficient resources and may not be able to comply with federal requirements. state officials do not understand why this program must be given priority when the backlog for other agencies is just as great. on the issue of appraisal fraud, an appraisal is an opinion of value which makes it difficult to show that the appraiser intended to deceive someone. for this reason, law enforcement officials often shy away from bringing fr