Texas Department of Licensing and Regulation

Property Tax Consultants Strategic Plan Comments

1. What are we doing well?
2. What can we do better?
3. If you could change one service that we provide, what would it be and how would you change it?
4. If you could eliminate or amend any provision of TDLR’s statutes or rules, which one would it be and why?
5. What major changes will occur over the next five years that will impact the way you do business and the services we provide?
1. What are we doing well?
  • All aspects of enforcement are very good, from the investigation of the violation to the final disposition.
  • Like the fact that TDLR is enforcing improper advertising and felt that TDLR investigators having a physical presence at auctions has also helped enforcement of the auctioneer rules and laws.
  • The Licensed Court Interpreters were pleased with the glossary of court terms on the exam page, the quick turnaround on providing information for reciprocity and course approvals and the quick e-mail response to questions.
  • Very efficient on licensing, the web site is easy and quick.
  • The licensing process is very good.
  • The renewal process works well.
  • Good communication.
  • Examination is good.
  • Licensing/registration and certification is going well and service is faster than before.
  • Scheduling and advertising continuing education classes.
  • I think you are doing well in all areas.
  • The Licensed Court Interpreter program is a model for other states around the country.  Congratulations.
  • I receive notices of administrative actions taken against violators of license rules.  Although I haven’t seen any in my own field, this tells me that the rules protect our jobs.
  • Complaint resolution, I was able to speak with a representative that was informative with updates to mistaken process.
2. What can we do better?
  • Identify contact person for specific auctioneer activities.
  • More effectively coordinate questions to the agency particularly between divisions. (AUC)
  • Provide better training of customer service representatives on auctioneer questions in the area of licensing.
  • Cut down on deflected calls – specifically 800 lines. (LCI)
  • Extend time period in which continuing education providers have to report from 14 days to 30 days. (LCI)
  • Increase the number of CSR’s to meet the demand of all license groups. (AUC & LCI)
  • Increase license period for continuing education providers.
  • Better job of enforcement. (LCI) (2 Dots)
  • Better job of data entry. (LCI)
  • Pay more attention to details on renewals on the front end. (LCI)
  • Educate folks about the need for auctioneers to be responsible for real estate auctions; coordinate with TREC. (1 Dot)
  • Improve the phone system so you speak with a live person.
  • TDLR did not receive renewal notice and then CE provider was not recognized. Delayed renewal for months.
  • Emailer personally filed several complaints, but there is a lack of follow up. Respondent is still unlicensed even after fines have been imposed.
  • More onsite inspection and review.
  • Better job of acknowledging receipt of complaints.
  • Seek stiffer penalties for non-licensed auctioneers.
  • Better job of investigating and prosecuting violations.
  • Offer Examinations in more convenient locations around the state.
  • Offer live web chats for persons with questions pertaining to laws and regulations.
  • CE service providers should offer classes more days than just Sunday.
  • You need to allow more flexibility in what’s accepted as continuing education.  Personal example – as a Ph.D. student in Foreign Language Education at UT-Austin, my coursework is basically all about language.  However, none of it counts for ce.  Not even my 2 graduate-level courses in translation count, although they cover both theory and practice.  In fact, none of the Spanish courses I took before count, despite also being at the graduate level (UTSA, enroute to my MA).  I see no reason for this.
  • I think that once you pass the written exam one should be given at least some type of license or certification to provide that one is able to translate written documents.
  • Like stated above, I have already taken the oral test two times.  I really do not understand how the points are tabulated for the results of this test.  How many points are needed to pass this test?  Is there any way you can prepare a test with conversations more common to the border between Mexico and the U.S. ?  in these two times I have taken the test words that are not so common in the border area are used and that is when one loses track of the conversations.  Do you think you can ask PSI to prepare a test more common to the U.S./Mexico Border?
  • Present educational programs on the licensing rules on court interpreting through professional associations for the professions of court administration and translation.
  • Communicate the requirements to the Courts and hold them responsible for adherence to the requirement of using licensed court interpreters.
3. If you could change one service that we provide, what would it be and how would you change it?
  • Review other continuing education processes such as State Bar that allows for the submittal of objectives and lesson plans. (LCI) (1 Dot)
  • Extend license period for CE providers from one to more years (2 to 3 years) *would not mind higher fee. (AUC, LCI) (2 Dots)
  • Allow for previous courses to be offered by providers. (1 Dot)
  • Limit on taking same CE course three consecutive renewal periods before you can take the same course again. (LCI)
  • Get credit for CE plus or minus 15 or 30 days from license renewal (allow credit for same course). (1 Dot)
  • Maintain the requirement for licensees to take different courses each year.
  • On-line renewals for LCI.
  • Questionnaire at time of renewal online. (LCI)
  • Re-evaluate the examination, particularly the pass rate, look at other states and pass rates. (LCI) (1 Dot)
  • Create court specific test – civil, criminal, etc. (LCI)
  • Maintain exam standard. (LCI)
  • Provide written exam to include foreign targeted language. (LCI) (1 Dot)
  • Oral exam orientation as a bridge between written and oral exams. (LCI) (1 Dot)
  • Create inactive status license similar to cosmetology. (AUC & LCI) (1 Dot)
  • Send list serve to inform instructors of ability to receive CE credit for courses taught. (AUC)
  • Allow pre-license education instructors to receive CE credit for courses taught.
  • Provide clearer, plain talk language in notices. (LCI)
  • Consider accepting CE courses from reciprocal states. (AUC)
  • Develop title act provisions similar to engineers.  (LCI & AUC) (1 Dot)
  • Audit CE providers once a year. (AUC) (1 Dot)
  • More detailed review of course material on front end. (LCI)
  • Use 3rd parties to assist TDLR in course material review, particularly in areas requiring more expertise. (LCI)
  • Further discussion about requirement for benefit auction, particularly license auctioneer following rules.
  • Enforce violations of Goodwill employees who conduct auctions and are unlicensed.
  • Change regulations for associate auctioneer’s license by allowing either two years of OTJ training OR auctioneer’s school.
  • Have “good standing” letters and all other forms available online to download/print.
  • Eliminate TDLR request to provide auctioneer information from other states.
  • Eliminate requirement that Auctioneer’s provide ss# to TDLR.
  • Create a joint Auctioneer/Real Estate License.
  • Establish guidelines to ensure that a DO or other manager at an auction company is actually involved in the day to day business of the company.
  • Eliminate 6 hours of continuing education.
  • Eliminate CEU requirements for auctioneers who have been in practice for a long time without any valid complaints.
  • Eliminate the education and recovery fee for auctioneers who have never generated a claim and double or triple it for those who have.
  • Eliminate “approved auctioneer school” requirement.
  • Reduce CE requirement from 6 hours to 3 or 4 and reduce cost.
  • Require Ebay auctioneers to meet same requirements auctioneers and auction houses have to meet.
  • Many CE programs are weak and do not offer education on standard court process and requirements or even require language fluency.  Please insist o higher standards for CE programs. 
  • I would appoint a court interpreter who is experienced in training and published in this field, who has at least 20 years experience to review the ce programs submitted by the providers.
4. If you could eliminate or amend any provision of TDLR’s statutes or rules, which one would it be and why?
  • Find a way for out-of-state license holders to do online continuing education rather than fly back to Texas.  That, plus the changes I mentioned above per flexibility, will be a step in the right direction.  It is unreasonable to have to pay airfare for a weekend course for a license renewal.
  • Please enhance the value of the license by stating the importance of interpreting skills and the definition of qualified as being trained and proven to educate the courts.
  • Without a doubt, it would be eliminate Sec. 59.30(a) Each continuing education course offered by a provider must be approved by the department before being offered. 
5. What major changes will occur over the next five years that will impact the way you do business and the services we provide?
  • Auctioneers were concerned that “E-Bay” type, on-line auctions and store front auctions will continue to blur the line of whether or not a person needs to be licensed.
  • Licensed Court Interpreters predicted an increase in the numbers of languages that will require interpreters along with an increase in telephonic interpretations.
  • Further tightening of financial documentation rules.
  • More use of online auctions, including live webcast auctions.
  • More use of E-bay could hurt licensed auctioneers.
  • The real estate market will be a huge one for auctioneers in the future, so consideration of a joint realtor/auctioneer license may come up.
  • There will be more estate auctions in the future as the baby boomer generation ages.
  • The decrease in court funding for interpreter fees will allow unqualified interpreters to take jobs away from skilled interpreters.
  • Appeals to state cases based on unqualified and unlicensed interpreters are increasing.  This should be tied into your inspection and review process.

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