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Draft Paper on Standardization of Procedure for Empanelment of Valuers

 
 

27th April 2015

 
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 "Draft Paper on Standardization of Procedure for Empanelment of Valuers" on which we Valuers have to give suggestions/ recommendations. It will help both Institution of Valuers, Delhi and Indian Bank's Association to prepare ideal policy for Indian Valuer as well as Banks & HFIs practicing in India.

 
 

Indian Banks’ Association
Draft Paper on

Standardization of Procedure for Empanelment of Valuers

  • Introduction
  • Valuation as a profession is an exercise falling primarily within the domain of economics as well as law. Valuation really concerns itself with all species of legal interests arising out of land and building as well as plant and machinery, which are exchanged for money and, therefore, entails the phenomena of exchange, scarcity and choice that characterizes a ‘market’ in the economic sense of the term.
  • It is utmost important that the valuers possess the requisite knowledge and experience.
  • The professions of civil, mechanical, electrical engineering, architecture, valuation of real estate and valuation of plant and machinery are independent of each other and in order to practice these professions academic qualification in respective disciplines is essential.
  • But there exists a peculiar situation in our country. Thereare less number of academically qualified valuers available in the country.Therefore, provision for empanelment is to be made in such a way that avacuum is not created and at the same time number of academically qualified valuers continue to increase over a period of timeand ultimately only academically qualified valuers shall be empanelled.
  • Criteria for Empanelment of Valuers including Qualifications

2.1       Educational Qualifications
It is necessary that a valuer possesses proper educational qualifications which makes him competent to carry out the task of valuation of immoveable property and plant and machinery. In addition, relevant work experience is also important.
Therefore, it is necessary to bear in mind following points while laying down criteria for educational qualifications:

  • Membership of professional body by passing an appropriate examination:

In case of S. K. Ahuja vs. CBDT-, the Allahabad High Court has held that the membership recognized by the CBDT for registration as a valuer should have been obtained by passing an examination by the applicant and therefore, after this judgment the CBDT made amendment to Wealth Tax Rules by inserting ‘Explanation 2’ which reads as under:
“Where the membership of any institution is recognized by the Central Government as a qualification for the purpose of recruitment to superior services or posts under the Central Government in any field, such membership shall not be regarded as a requisite qualification for the purposes of this rule, unless the membership has been granted on the basis of passing the examinations conducted by the institution.”
This clearly establishes that an educational qualification obtained by undergoing a regular course in respective disciplines from a recognized university is an essential parameter.
In view of the above, requirement of the membership of professional bodies laid down under the criteria for empanelment of valuers must stipulate that such membership is granted to the members who have passed the examination in respective disciplines of valuation.
As per Gujarat High Court decision in case of Institution of Valuers vs. Union of India - the disciplines of architecture, civil, electrical, mechanical etc. engineering, valuation of real estate and plant & machinery are different disciplines and independent of each other, in order to practice each one educational qualifications in each one is essential.
Therefore, for valuers,an academic degree in respective branch of valuation is stipulated.
Chartered Engineers and firms with engineering professionals shall only be empanelled provided they satisfy the condition of undergoing six months course/two week training as applicable by 31.12.2017 as stipulated later.

  • The valuers shall be empanelled in following two categories

(a)        Real estate
(b)        Plant & Machinery

  • The educational qualifications and experiences are laid down later.
  • Individuals or a group of individuals and partnership firms shall only be considered for empanelment for valuation of Fixed Assets.  (IBA shall examine the Wealth Tax Act, 1957, Section 34AB and ascertain whether Companies can be considered for empanelment as valuers.)

The LLPs may be permitted to empanel if they satisfy following condition:
Each of the partners of the firms must have academic degrees in respective disciplines of valuation and must satisfy experience criteria. The staff of LLP handling the valuation also should be academically qualified valuer in respective discipline.The report of real estate has to be performed under supervision of real estate valuer and similarly that for plant & machinery valuation under supervision of PM valuer.

  • Valuers should actively participate in the professional activities of the various professional bodies dealing with valuation of assets and should be registered with any of the following professional bodies. viz.,
  • Institution of Valuers,
  • Institution of Surveyors,
  • Institution of Government Approved Valuers,
  • Practicing Valuers Association of India,
  • The Indian Institution of Valuers,
  • Centre for Valuation Studies, Research and Training,
  • Royal Institution of Chartered Surveyors UK
  • American Society of Appraisers, USA
  • Appraisal Institute, USA.
  • The Valuer

- should also have PAN /Aadhaar and valid KYC documents,
- should be a citizen of India(it is essential to specify whether it includes or excludes overseas citizen of India(OCI) and Person of Indian Origin(PIO),
- has not been removed / dismissed from his services, or
- not been convicted of any offence and sentenced to a term of imprisonment.
- should not have been found guilty of misconduct in professional capacity
At the time of empanelment, the valuer shall give an undertaking to above effect.

  • The valuer should have through knowledge of issues to be considered in valuation of real estate as well as plant and machinery of industry concerned and also the types of assets to be valued.
  • The issues to be considered in valuation of real estate and plant & machinery are covered in the course curriculum of courses leading to the respective degree courses in valuation and most of them are not covered in civil, electrical,mechanical engineering courses which is evident fromextracts given belowfrom Para 33 of Gujarat High Court decision referred earlier:

“On a bare reading of the course prescribed for Master of Valuation in Real Estate, it is evident that the subjects pertaining to civil engineering are limited. In the first semester, except for elementary surveying which there does not appear to be any other subject related to the field of engineering. As regards the second and third semester, there are some subjects related to engineering, however, as rightly contended by the learned advocate for the petitioner, out of total credits of 34 in the second semester and 40 in third semester, the credits related to engineering are only eight in each of the semesters. Similarly, in the case of programme of Studies leading to the Master of Valuation in Plant and Machinery, the syllabus shows that the subjects related to mechanical or electrical engineering are limited to the extent of 8 credits out of 32 in the first semester; 10 credits out of 36 in the second semester and 7 credits out of 36 in the third semester. Thus, the syllabus makes it amply clear that the course in Master of Valuation does not predominantly pertain to any discipline of engineering.”

  • The individual / firm working as a valuer with the Debt Recovery Tribunals and High Courts would have preference in the empanelment.
  • Note:The important thing is that one must be familiar with various issues to be considered, possess knowledge of various methods of valuation and their application to different purposes of valuation. While empanelling it is essential to ensure that a valuer possesses the skillfor valuation of different types of Assets such as Land and Building, Plant and Machinery, and professionals specialised in the respective fields shall be empanelled. Therefore, it is essential thatonly valuers with academicqualification are empanelled with grandfathering provision.
  • For valuation of Land and Building, the Valuer should possess the following qualifications.
  • Immovable Property

Sr.No.

Educational Qualifications

Work Experience

1

Graduate/Post-Graduate degree in Valuation awarded by a recognized University in India

2 years workexperience in the field of valuation after completing the examination

2

Pass in Valuation Examinations conducted by the Institution of Surveyors, India (Valuation Branch)

2 years work experience in the field of valuation after completing the examination

3

Bachelor’s degree in Civil Engineering/ Architecture/Town Planning or equivalent.

5 years workexperience in the field of valuation after completion of the degree or equivalent.

4

Diploma in Civil Engineering / Architecture.

10years work experience in the field of valuation after completion of the diploma

5

Chartered / Professional membership of the Royal Institution of Chartered Surveyors (RICS) OR American Society of Appraisers (ASA) OR Appraisal Institute (AI), USAobtained
by passing an examination equivalent to examinations mentioned under sr.no. (1) & (2) above. In case of applicants who have obtained the degree in valuation outside India - they will have to complete a course covering Indian Laws in a stipulated time.

The work experience shall be same as  for sr.no.(1) and(2),i.e.2years.The membership of any institution should have been obtained by passing an examination in valuation equivalent to examinations referred in sr.no.(1) and (2)above. The examinations of these institutions should have been reviewed by Ministry of HRD, GOI from time to time.

 

From 1.1.2018 valuers shall be empanelled with academic qualification in valuation of real estate only.

The experience in valuation,considering various aspects of property like utility, marketability, transferability,physical, legal, social, economic etc., shall be considered as relevant valuation experience. In course curriculum of civil engineering and architecture these valuation aspects are not covered.

For existing or new empanelment of Valuers under category (3) above, they must complete either of the following prior to Dec 2017.

Obtain Master of Valuation (real estate) from any recognized university
                                                      Or
Pass final/direct final examination in valuation of real estate conducted by Institution of Surveyors (India) and recognized by Ministry of HRD- Govt. of India for recruitment to superior services
                                                      Or
Pass an examination in valuation of real estate equivalent toexaminations mentioned under sr.no (1) and (2) above conducted by the professional society like RICS, ASA etc. The examinations conducted by RICS, ASA should have been reviewed from time to time by Min. of HRD, GOI
                                                      Or
should complete 6 months prescribed course in Valuation in the subjects vital for valuation of real estate and notcovered in the civil engineering and architecture courses.
Note:The valuers falling under this category shall be allowed to continue on the panel even after 1.1.2018 provided they have satisfied the any one of the four conditionsmentioned above.

For existing or new empanelment of Valuers under category (4) above they must complete either of the following prior to Dec 2017

Pass final examination in valuation of real estate conducted by Institution of Surveyors (India) and recognized by Ministry of HRD- Govt. of India for recruitment to superior services
                                                                        Or
Pass an examination in valuation of real estate equivalent to examinations mentioned under sr.no (1) and (2) above conducted by the professional society like RICS, ASA etc. The examinations conducted by RICS, ASA should have been reviewed from time to time by Min. of HRD, GOI
                                                                        Or
should complete 6 months prescribed course in Valuationin the subjects vital for valuation of real estate and notcovered in the civil engineering and architecture courses

Note:The valuers falling under this category shall be allowed to continue on the panel even after 1.1.2018 provided they have satisfied the any one of the three conditions mentioned above.

For valuers who are already empanelled under category 3 and 4 above and having age exceeding 50 years as in Dec 17 must complete a 2 weeks prescribed course on Valuation.

  • Plant and Machinery

For valuation of Plant and Machinerythe valuer should possess the following qualifications.


Category

Educational Qualification

Work Experience

1

Graduate/Post-Graduate degree in Valuation awarded by a recognized University in India

2 years work experience in the field of valuation after completing the examination

2

Bachelor’s degree in Mechanical/Electrical/Production Engineering or equivalent.

5 years work experience in the field of valuation after completion of the degree or equivalent.

3

Diploma in Mechanical / Electrical/Production Engineering etc

10 years work experience in the field of valuation after completion of the diploma.

4

Chartered/Professional membership of the Royal Institution of Chartered Surveyors (RICS) OR American Society of Appraisers (ASA ),USA obtained by passing an examination equivalent to mentioned under (1) above. In case of applicants who have obtained the degree in valuation outside India - they will have to complete a course covering Indian Laws in a stipulated time.

The work experience shall be same for sr.no.(1),i.e.2years.The membership of any institution should have been obtained by passing an examination in valuation equivalent to examinations referred in (1) above. These examinations of the institutions should have been reviewed by Ministry of HRD, GOI from time to time.

 

From 1.1.2018 valuers shall be empanelled with academic qualification in valuation of Plant and Machinery only.

The experience in valuation,considering various aspects of property like utility, marketability, transferability, physical, legal, social, economic etc., shall be considered as relevant valuation experience.In syllabus of degrees in Mechanical / Electrical/Production etc.engineering, the above aspect are not covered, therefore, academic degree in valuation / 6 months prescribed course in Valuation / two week programme in valuation have been emphasized on similar lines of real estate.

For existing or new empanelment of Valuers under category (2) above they must complete either of the following prior to Dec 2017.

      Obtain Master of Valuation (plant & machinery)from any recognized university
                                                                        Or  
should complete 6 months prescribed course in the subjects which are vital for Valuation of Plant & Machinery and not covered in course curriculum of automobile,chemical,computer,electrical,.industrial,mechanical,production,textiles etc. engineering.

Note: The valuers falling under this category shall be allowed to continue on the panel even after 1.1.2018 provided they have satisfied any one of the two conditions mentioned above.

For existing or new empanelment of Valuers under category (3) above they must complete the following prior to Dec 2017.

should complete 6 months prescribed course in the subjects which are vital for Valuation of Plant & Machinery and not covered in course curriculum of automobile,chemical,computer,electrical,.industrial,mechanical,production,textiles etc. engineering.

Note:The valuers falling under this category shall be allowed to continue on the panel even after 1.1.2018 provided they have satisfied the condition of passing 6 months course referred above.

For valuers who are already empanelled under category 2 and 3 above and having the  age exceeding 50 years as in Dec 17must complete a 2 weeks training programme as prescribed.

(C) Agricultural Land

  • A valuer of agricultural land other than plantations should preferably be a graduate in Agriculture Science and must have worked as a farm valuer for a period of not less than five years. 

(D) Coffee plantation, tea plantation, rubber plantation

  • A valuer of coffee plantation, tea plantation, rubber plantation as the case may be should preferably be a Graduate in Agriculture Science and have worked as a manager of a coffee, tea, rubber estate or as the case may be. 

Note: Valuation issues to be taken into consideration while carrying out valuation of above assets are not covered in course curriculum of agricultural science,
2.3       Minimum Age Requirement

If the applicants satisfies the criteria for empanelment then age should not be bar.

2.4       Classof Valuers

  • The valuers  should be classified as under based on work experience:

Class of valuer

Work experience in undertaking valuations

Value of property for assignment of valuation work

A

More than 10 years

No limit

B

More than 5 years and less than 10 years

Up to INR 25 crore

C

Up to 5 years

Up to INR. 1 crore*

* In case of metropolitan cities, the limit shall be INR 3 crore.

The above criteria are based on chronological experience and same is not correct.
Valuation is a multi-disciplinary subject covering following subjects over and above the valuation:

Real Estate                                                    Plant & Machinery
Law                                                                 Law
Economics                                                      Economics
Finance                                                           Finance
Environmental Science                                  Environmental Science
Planning                                                         Planning
Building construction                                     Industrial Processes/Factory eq.

The practitioners in the field of valuation with more than 20 years’ experience are not aware of basic valuation maxims and hence do not use while preparing the valuation report. This is evident from the literature available in the country from articles published by the authors having more than 20 years’ experience as valuers of immovable property and have rendered services as Valuers of immovable property to the bank also for more than 10 years. These articles also establish that they also do not have exposure to basic issue of valuation maxims. Similar is the case for plant & machinery valuers.
A few of them are given below:

  •  “at an arm’s length” is explained by the author in the year 2014 as under, which is against the principle of valuation.

‘When we do the valuation of a specific property, we conduct market survey for a similar property in order to know the prevailing market rate for land, reasonable rent etc. Such property under comparison should be very nearer to the property under valuation or it should be ‘at an arm’s length.
If the property at a distant place is compared, then the value arrived at may not be nearer to the accuracy.’
Actually, at an arm’s length transaction’is one between parties who do not have a particular or special relationship, e.g., parent and subsidiary companies or landlord and tenant, that may make the price level uncharacteristic of the market or inflated because of an element of special value. The market value transaction is presumed to be between unrelated parties, each acting independently.
It has nothing to do with the ‘distance’. This is very basic and fundamental aspect which a beginner ought to know.
Now let us consider a case in which a transaction considered is very nearer to the property as suggested by the expert but it is between related parties then it will not satisfy the concept of willing buyer and willing seller and hence value worked out will not be as per S.5 (n) of Banking Regulation Act, 1949.
(b)        The difference in basic terms cost, price and value defined by the author are as under, which is wrong:
Cost is a fact.
Price is a policy.
Value is an Opinion.
Actually, cost and price are fact and value is an estimate of what price ought to be.
Can one not give opinion on cost, price as well as value? Certainly an opinion can be given on cost, price and value. Then the cost, price and value also become opinion.
(c)        An article suggests to carry out valuation, even in 2013, for probate as per Wealth Tax Rule 1BB on the basis of Bombay High Court judgement delivered in Aug.1982. Actually, Wealth Tax Rules have been amended with effect from 1.4.1989. Wealth Tax Rule 1BB is not in the statute book though author is recommending to use the method, which was already deleted from statute book 14 years back.
(d)        An award winning article on valuation under Land Acquisition Act, 1894 suggested payment of solatium at 15% whereas solatium amount was raised to 30% way back in 1984 (18 years before the article was published).
(e)        An article suggests to certify in the valuation report that – ‘legal aspects have not been considered.’
            Whereas, legal aspect is one of valuation maxims and has to be considered by a valuer.
(f)        An article published in 2004 has opined that ‘reversionary value’ of land is negligible in case of properties with new buildings and can be ignored.
This is absolutely wrong. Value of right of reversion depends on whether the occupier of the building is protected tenant or not protected tenant. Even if the building is old but occupied by a tenant protected under the rent act then also reversionary value will be negligible and can be ignored.

  • The article published in 2004 giving a case study – Valuation of properties partly tenanted and partly under self-occupation.

The case study is for a property located in Delhi.  The property has construction on Basement, Ground floor, First floor and Second floor each having built-up area of 2,250 sq. ft. Basement and ground floor are rented at Rs.3,15,000/- per month. The first and second floors are self-occupied.  Basement and ground floor are valued on rent capitalization method without considering value of right of reversion. First and second floor are valued on land and building method.
As per S.3(1) (c) of the Delhi Rent Act, 1995 premises fetching rent more than Rs.3,500/- per month are exempted from operation of the Act.  Hence the tenants of basement and ground floor are not protected under the applicable rent act and hence owner will get the vacant possession of the property after the period of tenancy is over.  Therefore, value of such property consists of –

        • Capitalized value of rent for unexpired period of tenancy.
        • Value of right of reversion of the property available after expiry of tenancy.

The author has not considered value of right of reversion and hence it is not as   per principles of valuation.        
Method of valuation adopted in the case study presented is as per Schedule III of Wealth Tax Act. The valuation under Schedule III is a statutory valuation specifically for Wealth Tax Act which does not satisfy the criteria of ‘Willing Buyer’ and ‘Willing Seller’ laid down in definition of market value.  As the valuation is required for bank finance Schedule III cannot be adopted as it does not satisfy S.5 (n) of Banking Regulation Act, 1949.
(h)        An article titled ‘present value of a cinema theatre’ states that the marketability is not considered.
In fact, marketability is one of the valuation maxims and value reported without consideration of marketability is improper.
(i)         An author has opined to carry out valuation of rented property as on 1.4.1981by land and building method, which does not satisfy ‘willing buyer’ and ‘willing seller’ concept.
(j)         In case of leasehold property with following data, an author has opined to carry out valuation by Schedule – III of Wealth Tax Act.

  • The unexpired period of lease is 55 years. The NMR is 10 lakh.

Solution by the author:
Unexpired lease period           =          55 years
Multiplying factor                    =          10
Net Maintainable Rent            =          Rs.10,00,000
Value of the property              =          Rs.1,00,00,000
In case of leasehold property two interests are to be evaluated, lessor’s as well as lessee’s based on the terms and conditions of the lease and the following points ought to be considered in order to estimate value of lessor’s and lessee’s interest in a property:
(i)         What is the lease rent?
(ii)        What is total lease period and unexpired period of lease?
(iii)       Whether lease is renewable or not?
(iv)       In case of renewal of lease, will lease rent remain same, as old or new rent will be fixed?
(v)        What amount will be payable to lessor as premium or capital investment in case of sale/assignment of property or extension of lease?
(vi)       On maturity of lease, if entire property reverts to the lessor or not if only land reverts then what will happen to building constructed by the lessee on the leased land? Will building vest free of cost with the lessor or the lessor has to buy from the lessee?

arge number of civil engineers retired from the government services, practicing civil engineers and architects possessing qualifications and experience in civil engineering and architecture have been registered as valuers under the wealth Tax Act due to shortcomings in the criteria for registration as valuers under Wealth Tax Act.
Since 1984, number of authors have expressed a need for training in valuation, a gist of a few is given below:

  • An article published in 1984, the author has emphasized the need for training in valuation by giving an example that an Architect who had absolutely no experience as a valuer got the registration as a valuer because he is a registered architect of the Institute of Architects and thus a registered valuer. But since last two years he had not finalized a single case of his own. In fact he finalized only one case that too was only by the author. The architect approached the author as he wanted training in valuation.
  • In 1993, a valuer empaneled by a bankstates as under:

‘I am a retired Superintending Engineer I am a novice in the field of Valuation. Recently I am appointed as panel valuer to a bank. I request you to guide me with regards to the procedure of valuation of property pledged to Bank as equitable mortgage.

From the above, it is evident that the situation in 1984, 1993 and 2014 remained the same except a breed of valuers with qualification in valuation has been developed after 1996 onintroduction of the courses in valuation disciplines by the universities.

In view of facts mentioned above, classification of valuers in category ‘A’, ‘B’ and ‘C’ needs revision. It should be based on quality of experience.

            2.5       Empanelment Procedure

  • In view of the foregoing discussions the procedure for empanel requires to be handled by the members of committee who can judge the qualification, experience and properly scrutinize the application; therefore it is essential that stalwart in valuation preferably academically qualified valuer is one of the members of the committee.
  • It is also in the interest of the bank to employ one academically qualified valuer to oversee the work of empanelled valuers like chartered accountants and lawyers employed in full time service.
  • All banks shall have a year round system of receiving application from intending valuers seeking empanelment. 
  • All such applications should be received in the prescribed format as per Annexure.
  • The application format shall also be available on the bank’s website and should be easily downloadable.
  • As and when the requirement arises, the number of valuers required shall be empanelled.Empanelment of the valuer should be done through a Committee approach. 
  • The scrutiny of the application of the valuer shall be done at the Regional / Zonal office and if the valuer is found to meet the eligibility criteria for empanelment, the application be forwarded to the Head Office of the Bank along with the recommendations of the concerned Zonal /Regional Office for consideration.  
  • On receipt of the application at the Head Office / Corporate Office, the application of the valuer shall undergo a final scrutiny and if found suitable the Head Office/Corporate Office may advise the concerned Zonal / Regional Office to prepare a panel of the valuers who would be empanelled as and when required by the Zone/Region. 

2.6       Duration of Empanelment

  • The duration of empanelment of the valuer shall be five years and once empanelled, unless and until removed from the panel.
  • However, the quality of service provided by the valuers shall be reviewed on periodic intervals by the banks.
  • Aperiodic Performance Review shall be carried out by a Committee comprising of Senior Executives of the Bank.  The Composition of the Committee shall be decided by the individual banks.If the performance is not satisfactory, the valuer can be depanelled at the discretion of the bank/HFI.

2.7       Removal of Valuers from Bank’s Panel

  • If the performance of the valuer is not satisfactory, the valuer can be removed from the Panel at the discretion of the Bank.
  • If a valuer is prima facie, found to have involved in some fraudulent activities / conspiracy with the borrowers/bank officials in over valuation of the property the name of the valuer should be reported to the IBA for placing it on the IBA’s caution list of Third Party Entities (TPEs) involved in Fraud.   Before reporting the name of the TPEs the bank shall ensure that the procedure laid down by IBA in its procedural guidelines are scrupulously followed.

2.8       Valuers need to furnish proof of experience.

Evidence of previous experience needs to be provided to the bank / housing finance institution.

2.9       Registration with Government –

Registration with the central / state governments is desirable but not compulsory.  However, it may be noted that for undertaking valuations under the SARFAESI Act, valuation has to be obtained from Registered Valuer under the Wealth Tax Act (Sections 34 AA to 34 AE). While assigning / outsourcing valuation work to valuers, it is necessary that banks take the provisions of the SARFAESI Act into account and comply accordingly.

In view of facts mentioned above, it is essential that lacuna in the SARFAESI Act must be rectified by rectifying the lacuna in registration of Wealth Tax Act.

2.10    References

Carrying out a reference check is extremely important in order to verify the competence of a valuer. Banks need to verify the quality of services provided by the valuer in the previous instances / reference checks before empanelling the valuers on their panel.  The referees shall be either (i) bank managers where previously the valuer had done valuations or (ii) companies for whom the valuer had previously done valuations.

2.11    Re-Empanelment

  • Valuers once removed from the panel of any bank or housing finance institution could be re-empanelled again after 3 years or a specified period as the case may be, based on the recommendations of the bank Conflict Resolution Committee. 

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