In Texas, a comparative market analysis (CMA) can be prepared by:
Question & Answer
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Only licensed appraisers
Restricting CMAs to licensed appraisers is incorrect because a CMA is not a formal appraisal; it is a market-based pricing opinion that falls within the authorized scope of services for all Texas real estate licensees, including agents.
Licensed real estate agents
Only brokers
Limiting CMA preparation to brokers only is incorrect because Texas law grants this authority to all real estate licensees, including sales agents operating under a sponsoring broker's supervision.
Attorneys only
Attorneys are not trained in real estate valuation methodology and are not authorized under Texas law to prepare CMAs as a standard professional service; this option has no basis in Texas real estate statute or TREC rules.
Why is this correct?
Under Texas law and TREC regulations, licensed real estate agents (as well as brokers) are authorized to prepare CMAs as a standard component of their brokerage services, such as advising sellers on listing prices or helping buyers evaluate offers. A CMA is not considered an 'appraisal' under Texas law and therefore does not require an appraiser's license, provided the licensee does not represent the CMA as a formal appraisal. This is consistent with the Texas Appraiser Licensing and Certification Act, which reserves the term 'appraisal' for credentialed appraisers but explicitly allows licensees to provide opinions of value in the ordinary course of their real estate business.
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