Not a Get Out of Jail Free Card
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In talking with Tim Andersen, a USPAP instructor and long-experienced appraiser, I was reminded that, even in the time of C-19, USPAP applies, and appraisals must still be credible. Reports must still not mislead. USPAP has never required the appraiser to inspect the property. That is a lender construct. So long as your scope of work is clear relative the level of inspection you provided, and why that was your scope of work, you should not have a problem.
Note that USPAP’s Certification Standards Rule, SR2-3 does not require you to disclose the extent of your interior inspection, since it does not require you to inspect the property at all. It merely requires you to disclose if you did not inspect the property. The GSE’s certifications are much more detailed, however. Thus, if you accept an assignment from a GSE, be prepared to carry-out the type of inspection it expects of you. If you are uncomfortable with that scope of work, then don’t accept the assignment.
It is not misleading to use a 1004 form for a desktop or a drive-by because, during these convoluted times, the GSEs and state boards know some of the rules have changed. Once the convoluted time have returned to non-convolution, the rules will likely change again.
If we continue to exercise proper due diligence, if our appraisals are still credible, if our report do not mislead the client or the intended user(s), then we are USPAP compliant.
For more information on this subject, please download and listen to The Appraiser Coach Podcast Episode: 527 Staying USPAP Compliant During The Pandemic