WHY DOES A REGISTERED VALUER NEED TO TRANSFER MEMBERSHIP BETWEEN RVOS?

Under the Companies (Registered Valuers and Valuation) Rules, 2017 and related IBBI circulars, a Registered Valuer (RV) can transfer membership from one RVO to another — but only with prior written permission from the Insolvency and Bankruptcy Board of India (IBBI).

1. Alignment With Professional Goals

Valuers may choose an RVO that better matches their professional specialization, network, or support structure. For example, some valuers prefer an RVO that is stronger in corporate law exposure, others in real estate valuation.

2. Asset Class Preferences

Each RVO may have different strengths or recognition in particular asset classes (e.g., Land & Building, Plant & Machinery, Securities & Financial Assets). Transferring allows valuers to align membership with their core asset class of practice.

3. Better Professional Services or Benefits

An RVO may provide better continuing education programmes, networking opportunities, mentoring, or other professional advantages that improve the valuer’s practice.

4. Strategic Career Positioning

Valuers may transfer to an RVO that has stronger industry recognition, better ties with banks and institutional clients, or more active promotion of valuers’ services.

Under IBBI regulations, every Registered Valuer must remain enrolled with a recognised RVO. But circumstances change — and that’s when transfer becomes necessary.

1️⃣ Better Professional Support & Services

Not all RVOs function the same way.

A valuer may shift because:

The new RVO offers stronger technical guidance
Better help in report vetting or compliance queries
More active professional forums & mentoring
Faster administrative response

👉 Example: A valuer facing repeated reporting queries joins an RVO known for strong peer review support.

2️⃣ Quality & Frequency of CEP Programs

Continuous Educational Programmes (CEPs) are mandatory.

Some RVOs:

Conduct more frequent CEPs
Offer specialized sessions (IBC cases, FEMA valuation, litigation support)
Provide online & offline flexibility

👉 A valuer who cannot attend physical CEPs may move to an RVO offering regular online & offline CEPs.

3️⃣ Change in Asset Class Focus

A valuer’s career direction may change.

For example:

Moving from Land & Building focus to Plant & Machinery
Shifting toward securities or financial assets
Entering niche sectors like infrastructure or insolvency valuation

Some RVOs are stronger in certain domains.

4️⃣ Geographical Convenience

Though RVOs work nationally, practical convenience matters.

Reasons include:

Local chapters
Regional workshops
Easier physical coordination when required

5️⃣ Administrative or Compliance Issues

A valuer may be dissatisfied due to:

Delay in membership renewals
Delay in CEP credit updates
Poor response in compliance matters

To ensure smooth regulatory standing, they may transfer to a more responsive RVO.

6️⃣ Reputation & Professional Visibility

Some RVOs have:

Stronger industry recognition
Better networking & opportunity guidance for empanelment in banks, NBFCs, IPs, and courts
Higher professional credibility

This can influence a valuer’s career growth.

7️⃣ Conflict or Disciplinary Environment

If a valuer feels:

Unfair treatment
Lack of proper grievance redressal
Internal disputes affecting professional work

They may opt to move to a neutral, professionally managed RVO.

8️⃣ Better Digital Systems

Modern RVOs may provide:

Online member dashboards
Easy CEP tracking
Downloadable compliance records
Quick NOC processing

Convenience matters in regulatory professions.

9️⃣ Career Growth & Networking Opportunities

Some RVOs actively:

Promote members for assignments
Conduct panel discussions with banks
Connect valuers with Insolvency Professionals

A valuer looking to expand professionally may switch.

🔟 Personal or Strategic Professional Reasons

Sometimes the decision is based on:

Alignment with professional philosophy
Recommendations from peers & friends
Long-term career planning

⚖️ REGULATORY NOTE

Transfer is allowed only with the proper procedure:

NOC from existing RVO
Acceptance from the new RVO
Intimation/approval as per the IBBI process

A valuer must always remain enrolled with an RVO — a gap in membership can create compliance issues.

🎯 In Simple Words

A valuer transfers RVO membership to ensure:

✅ Better professional ecosystem
✅ Stronger learning & CEP support
✅ Smoother compliance
✅ Improved career opportunities
✅ Professional comfort and growth

Key Regulatory Requirement

A registered valuer must always remain a member of an RVO recognised by IBBI. Loss of such membership without transfer may lead to cancellation of IBBI registration, as the eligibility condition under the Rules is no longer met.

POINT-WISE PROCEDURE FOR TRANSFER OF MEMBERSHIP (AS PER IBBI GUIDELINES)

The transfer procedure is governed by IBBI Circular No. IBBI/RVO/029/2020 dated 28th January 2020. The process below applies to a Registered Valuer (already registered with IBBI and enrolled with an RVO).

Subject: Transfer of Membership from one RVO to another.
The Companies (Registered Valuers and Valuation) Rules, 2017 (Rules) envisage Registered Valuer Organisations (RVOs) to act as front-line regulators for development and regulation of the valuation profession. They have the responsibility to admit, groom, monitor and discipline the members of the profession, and while doing so, they must follow well established norms of governance befitting a regulatory State. Keeping their responsibilities in view, the Rules prescribe the composition of Governing Board of an RVO, and manner of discharge of its powers and functions. The reputation of the valuation profession and the professional members hinges on the reputation of the RVO concerned. Being the new entities in the regulatory space, the conduct and performance of RVOs are being watched very closely by the stakeholders.
2. The Rules envisage a competitive industry of RVOs, where they compete with one another to provide better valuation services through their professional members, in the interest of the users, and other stakeholders of valuation services. The Rules also envisage that a member may shift membership from one RVO to another, subject to prior permission of the Authority, that is, the Insolvency and Bankruptcy Board of India (Board) for the same. The Rules further require an RVO to employ fair, reasonable, just and non-discriminatory practices for enrolment and regulation of its members.

3. It has been repeatedly brought up by the RVOs in the various meetings that the Board is having with MDs/CEOs of RVOs on the 7th of every month, that a few RVOs are restricting transfer of membership by using dilatory tactics, charging unreasonable transfer fees, etc. It has been the endeavour of the Board that the RVOs mutually agree to a mechanism for seamless transfer of a member from one RVO to another. It has been impressed on them to avoid restrictive and unreasonable practices and to allow transfer of membership expeditiously, after recovering dues, if any, pending from the member concerned and charging a reasonable fee to cover the expenses on transfer. However, the problem persists.
4. In order to streamline the process of transfer of membership from one RVO to another, the RVOs are directed to follow the process as outlined under the Tables below:

STEP 1 — Apply to Your Current RVO (RVO-1)

The Registered Valuer must submit an application to RVO-1 (the RVO where they are currently enrolled) seeking No Objection Certificate (NoC) for the transfer of membership.

The application should include:
✔ The prescribed transfer fee not exceeding the amount set by RVO-1 (max Rs. 1,000/- under typical practice).
✔ All dues, if any, owed to RVO-1.
✔ Original membership certificate.
✔ Original IBBI registration certificate.
✔ Original Certificate of Practice, if any.
✔ A statement of ongoing assignments under the Rules.
✔ A declaration that no disciplinary proceedings are pending against the valuer with RVO-1 or IBBI.
✔ A statement of any pending complaints against the valuer.

STEP 2 — Review and NoC by RVO-1

Within 7 days of receipt, RVO-1 must either:
📌 Issue the No Objection Certificate and forward the application to the IBBI, along with its views on the transfer.
OR
📌 Inform the valuer of deficient documentation.

If RVO-1 does not respond within the timeline, a deemed no-objection may arise under the timelines specified in the circular.

STEP 3 — IBBI Decision

After receiving RVO-1’s recommendation, the IBBI must decide within 7 days whether to:
✔ Grant permission for transfer; or
✔ Refuse permission with reasons.

STEP 4 — Apply to New RVO (RVO-2)

Once the valuer receives IBBI’s permission, the valuer must apply to RVO-2 (the new RVO) for enrolment, attaching the IBBI transfer permission.

STEP 5 — Enrollment by RVO-2

RVO-2 will process the enrolment per its normal admission processes. Upon successful enrolment, RVO-2 notifies the IBBI and RVO-1, confirming the valuer’s date of enrolment.

STEP 6 — Update of Records

Upon notification, the IBBI updates its records, issues a fresh registration certificate, and confirms the same to the valuer, RVO-1, and RVO-2.

Important Interim Rule

From the date of application for transfer until the date the valuer is enrolled with the new RVO, the valuer must not take up any new assignments.

Key Points to Keep in Mind

✔ Prior permission from IBBI is mandatory for any membership transfer, whether before or after registration.
✔ Membership is a continuing condition for IBBI registration — losing it without transfer can lead to cancellation of registration.
✔ RVOs must act in a fair, reasonable, just, and non-discriminatory manner while processing transfer requests.
✔ The timelines set out in the IBBI circular ensure an expeditious process to avoid unnecessary delays.

From the date of applying for transfer
↓
Until enrolment with RVO-2 is completed
↓
❌ Valuer MUST NOT accept any new valuation assignments

✅ CHECKLIST – TRANSFER OF MEMBERSHIP FROM ONE RVO TO ANOTHER (FOR REGISTERED VALUERS)

🧾 PART A – BEFORE APPLYING FOR TRANSFER

☐ I am a Registered Valuer (RV) with a valid IBBI registration
☐ My membership with the current RVO (RVO-1) is active
☐ I have identified the new RVO (RVO-2) I wish to join
☐ I have reviewed RVO-2 eligibility criteria and admission rules
☐ I understand that IBBI prior approval is mandatory

📂 PART B – DOCUMENTS TO SUBMIT TO CURRENT RVO (RVO-1)

☐ Application letter requesting No Objection Certificate (NoC) for transfer
☐ Prescribed transfer fee paid (as per RVO-1 rules)
☐ No dues confirmation from RVO-1
☐ Original RVO-1 Membership Certificate
☐ Original IBBI Registration Certificate
☐ Original Certificate of Practice (CoP) (if issued)
☐ List of ongoing valuation assignments as on date of application
☐ Declaration stating no disciplinary proceedings pending with RVO-1 or IBBI
☐ Details of any pending complaints (if applicable)

🏢 PART C – ACTION BY RVO-1 (FOR YOUR FOLLOW-UP)

☐ RVO-1 reviewed the application within 7 days
☐ RVO-1 issued No Objection Certificate (NoC)
☐ RVO-1 forwarded the application and recommendation to IBBI

🏛️ PART D – IBBI APPROVAL STAGE

☐ IBBI granted written permission for transfer
☐ I have received official communication/email from IBBI
☐ I understand that without IBBI approval, the transfer is not valid

📝 PART E – APPLICATION TO NEW RVO (RVO-2)

☐ Application for membership submitted to RVO-2
☐ Attached a copy of the IBBI approval for transfer
☐ Submitted all documents required under RVO-2 enrolment rules
☐ Paid RVO-2 membership/enrolment fee

📢 PART F – AFTER ENROLMENT WITH RVO-2

☐ Received confirmation of enrolment from RVO-2
☐ RVO-2 informed IBBI and RVO-1 about my enrolment
☐ IBBI issued an updated / fresh Registration Certificate
☐ My RVO details are updated in IBBI records

🚫 CRITICAL COMPLIANCE REMINDER

☐ From the date of applying for transfer
➡️ Until enrolment with RVO-2 is complete
❌ I have NOT accepted any new valuation assignments

🔍 FINAL SELF-VERIFICATION

☐ I remain a member of at least one recognised RVO at all times
☐ There is no gap in membership that could affect my RV registration
☐ All records and certificates are safely preserved