Increased Regulatory Persecution of Appraisers

Increased Regulatory Persecution of Real Estate Appraisers - USPAP

The current and proposed revised version of USPAP also opens the door to increased regulatory persecution of licensed and certified real estate appraisers, while leaving all others that opine about values with no constraints, rules or limitations.

I was recently asked to consider a proposed change to USPAP. As received in my email:

“Also this, in the 3rd exposure draft

  • 239 The appraiser is not required to title an appraisal report using specific terminology because
  • 240 USPAP compliance is measured by the substantive content of a report, not by what the
  • 241 report is called. The use of labels such as analysis, consultation, evaluation, study, or
  • 242 valuation does not exempt an appraiser from adherence to the Uniform Standards of
  • 243 Professional Appraisal Practice.
  • 2382 APPRAISAL: (noun) the act or process of developing an opinion of value; an opinion of value.,
  • 2383 which is numerically expressed as a specific amount, as a range of numbers, or as a relationship
  • 2384 (e.g., not more than, not less than); (adjective) of or pertaining to appraising and related functions
  • 2385 such as appraisal practice or appraisal services.
    • 2386 Comment: An appraisal must be numerically expressed as a specific amount, as a range of
    • 2387 numbers, or as a relationship (e.g., not more than, not less than) to a previous value opinion
    • 2388 or numerical benchmark (e.g., assessed value, collateral value)

And FDIC’s definition

FDIC’s Interagency Appraisal and Evaluation Guidelines (AKA Agency) definition of appraisal:
Appraisal— As defined in the Agencies’ appraisal regulations, a written statement independently and impartially prepared by a qualified appraiser (state licensed or certified) setting forth an opinion as to the market value of an adequately described property as of a specific date(s), supported by the presentation and analysis of relevant market information.

Shouldn’t USPAP’s definition be similar to FDIC’s?”

So, it’s a great question. Short answer is yes. It should be. In my opinion.

Like so many other short notice research tasks this issue went in a direction of its own. One thing leads to another. One question generated many more. Starting with “who comes up with this stuff?”

Obviously, the ASB formally makes the proposal. In 2018 That collectively meant the six members of the 5 to 9 member authorized Appraisal Standards Board, reported on the TAF site as:

  1. Wayne R. Miller, MAI, ASB Chairman, General Certified Real Estate appraiser and a Supervisor of a large bank’s commercial appraisal review staff;
  2. Patricia Atwood, ASA, a Personal Property Appraiser
  3. Michelle C. Bradley, General Certified Appraiser and a representative of the National Association of Realtors®, performs review appraisals for the PA Dept of State and serves as the NAR rep to TAFAC (in effect indirectly supervising her own TAF board?)
  4. Lisa Desmarais, MNAA, and Certified Residential Real Estate Appraiser. SFR appraiser and investigator (contract?) reviewer for CO Dept of Regulatory Agencies Div. of R.E. I’ve spoken with Ms Demarais in the past and hold her in high esteem. This isn’t a negative inference about the others. I simply don’t know them.
  5. Robert (P) Reardon, MAI, MA General Certified Appraiser
  6. Roberta (Anne) Ouellette, Attorney. NC Appraisal Board Member, AARO member or presenter (see link). Believes opinions have little or no credibility, and apparently that “fact based” data is never subjective. She may be the actual source of the misguided teaching trends prevalent among state investigators concerning USPAP, seemingly promoted by TAF and AARO.
  7. Margaret Hambleton was the Chair on 12/18/2018. I don’t have the dates of transfer from or to #1 to #7 or #71 to #1. The TAF website is not fully up to date.

Also, be very sure to read TAF-ASB Member, NCAB Member, AARO-Member, Attorney Roberta (Anne) Ouellette’s ‘opinion’ on opinions… it clarifies why some of the trend toward prosecutorial focus rather than professional appraisal focus is increasingly found in USPAP and state regulatory agencies nationally. It may help explain why existing sections of USPAP about perfection being impossible to achieve have disappeared in the revisions; and the way we are increasingly seeing the term “prove adjustments” rather than “support adjustments” by data science purveyors & ill-advised reviewers.

So, for the purposes of clarity and better understanding we are supposed to accept that USPAP changes concerning a defined opinion (appraisal) must now be factually proven? That no human margin for error is expected at all? Ever?

I must confess, I still have a very old and apparently antiquated idea of how an appraisal is or should be defined.

Appraisal (verb): The act of developing a credibly developed & supported, unbiased opinion of a specifically defined value for a specifically defined interest in real estate as of a specific point in time in accordance with USPAP and or other specified generally accepted sound real estate appraisal practices [1]. (noun) The written or oral result(s) of an appraisal. Ms Ouellette of TAF ASB clearly disagrees.

I do NOT consider other valuation disciplines interpretation of appraisal to have any degree of relevance to real estate appraisal. Nor did Congress when they authorized the creation of The Appraisal Foundation (TAF) and authorized it to develop the Uniform Standards of Professional Appraisal Practice.

The Appraisal Institute’s Dictionary of Real Estate Appraisal [2] uses the TAF’s first tortured iteration 2010-2011.

“1. The act of process of developing an opinion of value. 2. An opinion of value.”

I’m not going to quibble with 9-year-old definitions except to state that if we are going to use bare bones, overly broad definitions; originally intended to redefine real estate appraisal terminology to be more palatable to other valuation disciplines, then we must also introduce the concept and terminology of “Credible Real Estate Appraisal” and filter out everything else… Such as an undefined “Appraisal” reported in whatever non-uniform, variable, nonstandard, abbreviated, nonsensical format any client chooses to impose; or lazy appraiser chooses to perform. The more variants, the better. To preserve the public trust no doubt.

While I strongly prefer some variant of my own suggested definition, I’m perfectly happy to accept the Interagency definition. Both are more definitive and incorporate fundamental requirements into the very definition, than USPAP does.

One possible enhancement would be to state that an appraisal is also prepared for a specified client and does not include any opinion offered in verbal discussions with parties that are not clients of the appraiser, or where there is no specifically stated intent to provide an appraisal. For example, in purely social discussions among friends or acquaintances where there is no reasonable, & contractually legal reliance on the discussion. Currently appraisers First Amendment rights are unreasonably limited beyond any other members of the public, because of a misguided belief that anytime we open our mouths and say a number or range related to any real estate, we have performed an appraisal.

We may be the only profession claimed to have delivered a professional product anytime we speak. To protect the public trust?

The 2010 USPAP, current version & proposed Appraisal Definition revisions leave loopholes big enough to drive a fleet of hybrids through.

Treating them just as if they were real appraisals.

In fact, many, if not almost all the proposed revisions to SR1 and SR2, and definitions appear to be intended to facilitate the use of non-appraisers, and less than traditionally professionally acceptable ‘valuation’ products.

Products that could assist the automated valuation hucksters and the ‘no credible standards at all’ advocacy interests. Read the related sections of SOW Rule, SR1 and SR2 about depth of research, inspections, significant assistance, etc. To promote the Public Trust?

This is a great point to remind readers of the history of financial regulation dating back to the 1970’s. Note the recurring theme. Every single time that prudent regulations were cut back or eliminated, financial disaster and or wide spread fraud resulted.

The current and proposed revised version of USPAP also opens the door to increased regulatory persecution of licensed and certified real estate appraisers, while leaving all others that opine about values with no constraints, rules or limitations.

Licensed or Certified Appraisers will apparently be held to a standard requiring perfection now. While non-licensed, unregulated real estate “appraisers”, valuators, evaluators, inspectors, brokers, Ouija Board Operators, Data Aggregators and Mathematicians can “cite science” and the infallibility of “Big Data” and offer any spurious value they want with no repercussions. In fact, they are now uniformly allowed to call these spurious value-guesstimates “Appraisals” all over America and online. No doubt, to preserve & promote the public trust. Or, the myth to that effect.

If one reads the motivation behind the numerous unnecessary USPAP changes, “…increased enforceability thereby promoting or preserving the public trust” is always the stated driving force. Untrue verbiage about enhanced understanding is also usually included… even when the revisions obviously have or likely will have the opposite effect.

Ease of understanding has never been an objective of USPAP. At least not since 1991.

I’ve always wondered how TAF defined ‘Public Interest’ or ‘Public Trust’.

While not widely known, TAF did offer public explanation at least once. Please note the SUBJECTIVE >OPINIONS expressed in their explanation still did not define it.

“USPAP Q&A reports

Question: The expression “public trust” is used in USPAP. What is public trust and who or what is the public in the USPAP context?

Response: USPAP mentions public trust three times. The PREAMBLE states that the purpose of USPAP is to “… promote and maintain a high level of public trust in appraisal practice by establishing requirements for appraisers.” The PREAMBLE also states “The appraiser’s responsibility is to protect the overall public trust and it is the importance of the role of the appraiser that places ethical obligations on those who serve in this capacity.” Lastly, the ETHICS RULE reinforces this concept with “An appraiser must promote and preserve the public trust inherent in appraisal practice by observing the highest standards of professional ethics.”

While USPAP does not define public trust, it is clear from the context that it refers to the need for the public to be able to have confidence that services provided by an appraiser are performed competently and in a manner that is independent, impartial, and objective.

The public, whose trust the appraiser must promote and preserve, exists on several levels. The most direct is the appraiser’s client. In addition to the client, any additional intended users would be part of the appraiser’s public. But, even beyond the client and other intended users, there are other parties who may rely on the work an appraiser and the appraiser must be careful not to mislead such third parties. Finally, it could be said that the general public is also part of that public. If the general public cannot depend on appraisers to act as independent professionals and provide credible results, the economy could suffer.

Source: The Appraisal Foundation [Refer back to Ms Ouellette’s linked PowerPoint outline on opinions at the beginning of this article].

Another document that does not define, or even mention the Public Trust in real estate appraisal, is FIRREA itself. A 1991 Fordham Law Review article by Anthony Providenti Jr provides an in-depth explanation of what FIRREA was created to do:

Playing with FIRREA, Not Getting Burned: Statutory Overview of the Financial Institutions Reform, Recovery and Enforcement Act of 1989

Readers can see that the closest reference is a subsidiary goal of restoring public confidence in the failed S&L system… not real estate appraisal. The goal was to restore confidence in the egregiously deficient financial industry… not the real estate appraisal profession.

The phrase(s) “Protect the Public Trust” or Promote the Public Trust have been invented by TAF and others. Not by Congress in FIRREA. It’s a paraphrased concept of restoring faith in a failed lending industry that was usurped in order to support whatever half-baked idea TAF or any of its sponsors, or The Appraisal Foundation Advisory Council (TAFAC) members, or AARO come up with, or adopt behind closed doors.

TAF says that “The goal of the Uniform Standards of Professional Appraisal Practice (USPAP) is to promote and maintain a high level of public trust in appraisal practice by establishing requirements for appraisers.” [3]

That goal may arguably have been achieved in the earliest 1991-(circa) 1994 USPAP version. Ever since, that result has grown further distant until we get to the present day.

A time when Zillow; Trulia, RealAVM, ClearVal, and a host of other Mickey Mouse-esque, spurious & unreliable valuation methodologies routinely claim they are just as good; almost as good or even better than real appraisals. They’re certainly cheaper!

Collectively AVMs, these products are now routinely believed by the general public to be the same or better than real appraisals. Lenders also routinely encourage appraisal waivers where allowed under the pretext that alternative methods are just as reliable to confirm market value. Are they not also part of the pubic whose trust had to be restored and maintained?

Great job of promoting and maintaining the public trust in appraisal practice TAF! In a mere 27 years you have single handedly driven down the public’s trust in appraisal practice to near zero. Heck, you have driven down appraisers’ trust in the appraisal process under USPAP, and as currently enforced.

After 27 years, USPAP is still not right! Is there any other corporation in America today, that would be allowed by the market to exist after 27 years of failing to achieve their mandate? Or alternatively having reasonably achieved it in the first year, spent the next 26 destroying what had once been achieved? Absent federal subsidy, could TAF exist another year?

We went from $50 billion in losses from the S&L crisis, to over $1.5 trillion under TARP. These are not records The Appraisal Foundation should be seeking to exceed. Another 30-fold increase would exceed all current RE Value in the country.

Though it will be time consuming, I urge all appraisers reading this to go through each of the proposed USPAP changes and send your written concerns to:

Margaret Hambleton, Chair
Appraisal Standards Board
The Appraisal Foundation
1155 15th Street, NW, Suite 1111
Washington, DC 20005

All should cc Mr. Jim Park, Executive Director, Appraisal Sub Committee

Be as factually accurate as possible, but nice in your comments. While TAF states the members of ASB will read ALL comments, and that those comments will be posted for the public they also add a NOTE: that they reserve the right to not post any comments that they subjectively opine to be offensive or contain inappropriate statements.

I’m not certain if comments critical of TAF or AARO are considered ‘inappropriate’.

Apparently ‘opinion’ (“a view or judgment formed about something not necessarily based on fact or knowledge”) is deemed valid, and permitted at TAF.


  • [1] As accepted and regularly utilized by respected professional real estate appraiser peers
  • [2] Fifth edition, citing USPAP 2010-2011 ed.
  • [3] ASB Chair Memo dated 12/22/2018 RE 3rd Exposure Draft for proposed changes to 2020-2021 USPAP

Michael Ford
Latest posts by Michael Ford (see all)
Michael Ford

Michael Ford

Over 28 years appraising all property types and interests, in Southern California real estate. VP/Chairman National Appraiser Peer Review Committee, American Guild of Appraisers, #44OPEIU/AFL-CIO. - Michael Ford on e-AppraisersDirectory

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21 Responses

  1. Avatar chris says:

    So sad !! It is called the dumbing up of America. Profit, profit, and more profit!!!  They have wanted us gone for 30 years !

  2. Baggins Baggins says:

    Another vital lesson for us younger appraisers. Agreed that it’s an unreasonable industry requirement to ask appraisers and related non appraisers to keep up with this never ending living document nonsense. Ethic is supposed to be a modern reflection of strict morality and is not something which is flexible and so easily reformed for the purpose of pleasing and incorporating new special interests. Ethic in its most simple form is a question of right vs wrong and it is always wrong to sell another person short for personal gain. Back to the basics. Thank you.

  3. USPAP should change maybe once a decade. And only then, it should be lightly revised. Fundamental principles don’t change.

    One big problem is USPAP gets its funding BY changing. They collect our fees for having to purchase the book. Even though they offer a free version online, they MANDATE all students MUST have paid for the book.

  4. Ross Grannan on Facebook Ross Grannan on Facebook says:

    Interesting, the “case” referenced is pretty glaring example of a violation of USPAP, of course everything about it is subjective

    • I chose not to get into the case specifics. Obviously, no one giving a public presentation submits case data that conflicts with their views.

      I’m far more concerned about the language of absolutes replacing experience based opinions as if they were four letter words now. Note how the entire requirements under SR3 and SR 4 appear to have completely disappeared from the regulators perspective?

      Those whose job it is to determine our USPAP compliance cannot be bothered to follow those same MINIMUM standards for federally regulated transactions. Since state reviews are not for FRTs they get to pick any undefined standard they choose…including making them up on the fly. (Proof of statement is available in the transcripts between BREA and my own case – a whole DVDs worth of text)

      • Ross Grannan on Facebook Ross Grannan on Facebook says:

        So what you are saying is they make it up as they go along, with the constant changes of USPAP it’s difficult for most appraisers to stay on top. USPAP is like toilet paper now. The case example is an obvious violation, it’s the method of “prosecution” that is alarming. They choosing to ignore any subjective appraisal opinion as relevant if they choose

        • Absolutely they make it up as they go along! I have court transcripts to prove that contention; as well as all my other claims about BREA (CA); and almost as much for MD. Where the stat continued to persecute even though we proved they were wrong about the main issue in contention (and all the others were non-issues they piled on).

          The ONLY guide states need to investigate USPAP violations is the Tad Whitmer (MAI) article and summary in workingRE on reviewing.

          THIS is what happens when state bureaucrats sidestep their own state legislators and adopt ‘policy’ through back channels with private corporations (TAF).

  5. Avatar TvZ says:

    They (regulators, lenders, software co’s etc…) demand more every year while the appraiser gets less and less each year. Regulators should be spending time looking into the methods in which AMCs blast out fee requests so as to assign appraisals to the lowest bidders. Example, I was approached to appraise a custom 12,500 sqft home that had recently sold for $7,000,000, they offered $350. I told them it would be $1500 minimum and never heard back. Or, recently an appraiser I know who has resorted to driving for Uber to cover the costs of having a child with disabilities in the midst of the slowdown recently bid $225 in response to an AMC’s email blast to find the lowest bidder to appraise a $1,300,000 property sale in Orange County, CA – someone bid lower. So, while I appreciate the topic… Yes, let’s get caught up in discussing changes to USPAP while the values comprising one of our country’s largest asset classes is being assigned to folks willing to work for minimum wage, with no benefits or job security. The industry is joke.

    • Baggins Baggins says:

      They are a regulated set of entities. Where is their ethics book? Suspiciously absent. The uspap book developers refused to acknowledge the emerging problems and never properly covered updating the management rule (providing a thing of value to be the preferred selectee in relationship to variable amc fee raking and quoting), or properly covered the issue of outsourced labors and known threats to data and citizen security using both overseas services and non licensed help. Calamity ensues. If the federal lending industry and all their insurers are going to rely on evals, there needs to be a third ethics book and new regulatory oversight structure and licensing program for the tech nerds. That is the next logical step as it’s inevitable someone on that side will drop the ball in a major way eventually. The solution will of course be a larger government and additional licensing schemes. Logic indicates sticking with traditional full service appraisal makes entirely more sense all around. If people can’t see this coming a mile down the tracks, they are blind. Expansion of government from self created problems happens before and is happening again right in front of our eyes. My crystal ball is telling me that is a great way to eliminate all emerging eval competition, and that’s why this ‘industry’ waited until it was sufficiently monopolistic already before moving to subvert the traditional appraisal industry.

      Prove me wrong. Change my mind.

    • It’s so interesting you mentioned this. This week I was offered a $15MIL, 8,500SF SFR in Atherton for a fee of $385. I counter bid the exact same you did, $1,500 (I bid lower as it was an AMC). I also explained in my counter that none of my non AMC lender clients would even think to try and order this for less than $1,500 (I had done three in the past year for two different lenders for between $2,000-$2,750). The “vendor coordinator” emails me to ask if I can please explain what validates such an outrageous fee? Outrageous? I said would you care to explain what kind of fee quotes you’ve been receiving for these types of orders? The response was, “I cannot divulge this information, but I can say that your bid is over double what our other appraisers in the market are bidding.” If this is true, who are these appraisers?

      Appraisers need to collaborate to set fee standards. I’m still not able to charge any more for your average run of the mill small retail building San Francisco, than father charged 20 years ago. Why haven’t “acceptable” fees kept up with inflation? Why are we charging the same fees we were 20 years ago? It’s insane. I guess maybe I’m insane for continuing in the profession.

      • Baggins Baggins says:

        This problem is rooted in the contingency fee prohibitions. Before interjection by middle managers it was common place for lenders to have fee tables by housing price, properly recognizing increased home size and cost normally justifies higher vendor fees due to complexity and time to develop. Often these vendor fee scales were based on home size, not cost, but not always. The contingency fee prohibition was in place to eliminate bias which could occur if an appraiser scooted the final value number up slightly to then attain a slightly higher fee, per the established fee scales, as lenders had variable criteria for these internal cost lists.

        There is nothing wrong with scaling fees, as long as the fee is established up front before the value opinion provided. Another misinterpreted guideline which is made possible due to the absence of ethical requirements for amc service terms and billing structures. The distributor bias is of course because there is no requirement for cost plus billing or returning fee savings to borrowing consumers. Parties would likely be surprised if they learned the lenders still maintain such fee schedules but have abdicated their appropriate oversight requirements and simply trusted the amc to be fair. Cost plus billing would solve this issue. The potential harm to consumers who’s lenders utilize amc’s are elevated in the jumbo realm.

        The practice of unrestrained fee raking without returning cost savings to borrowing consumers has now spread to direct distribution areas as well. The all in one solution must require completely separate billing regardless of amc or direct, regarding appraisers fees and processing costs. These days many direct distributor outlets fund the assignment positions via a cut of the total appraisal service fee. Mortgage bankers used to accomplish this task free of any additional charges to the consumer. For insight regarding the apparent ignorance of amc assignment clerks, one only needs to review their continual job posting advertisements.

      • Avatar TvZ says:

        The $750 fee appraiser most likely has no credible experience appraising properties in the class of real estate that you do! (ocean front, highest quality customs, high rise penthouses, etc…) And, that is my point! The appraisal mis-management co’s put your name on their “list” of appraisers to look good as they hustle up more lenders but, they will never ever hire you at anything close to your fee.

        The mis-management co’s are nothing but another regulator creator catastrophic element in the final chapter of another American profession that has been burned to the ground in the name of technological advancement, or more truthfully because too many big guys noticed too many average Joes making pretty decent money.

      • 1, The AMCs fee is the only thing outrageous!. For ranges you cited I’d be in the $1,500 to $3,000 range…and sometimes as high as $4,500. It all depends on complexity AND anticipated exposure.

        If I’d do a job for a private party or bank at $1500…for court it would be $2500. WITH GOOD REASON!

        I personally don’t see how anyone anywhere in America can get by on less than $550-$650 for a non-complex sfr…but then again, I’d never suggest that $550 be the bare bones minimum because that would get the FTC all hot and bothered.

    • Avatar Chris says:

      No one bid lowered into 225, it’s all bs on the side of the I AMC, they will take the lowest quotes and use them as evidence of what customary and typical fees are, that’s all it’s about !!!

  6. Avatar TruthBTold says:

    Yes, Mike, this is the most troubling of all, to me. Regulators are making everything absolute, in a variable world. No matter how hard we try, they will always have some very specific, exact rule that they can point their finger at and say, we are not USPAP compliant.

    • It appears that one ‘regulator’ in particular, Ms Roberta Anne Ouellette may be leading the charge or at least one of it’s more visible proponents. She is NOT an APPRAISER. She is a member of The Appraisal Standards Board (ASB) of The Appraisal Foundation (TAF). She is also an attorney for the North Carolina Appraisers Board (NCAB), and past presenter to AARO (see above article).

      One thing is exceptionally clear from her powerpoint presentation above. She doesn’t have a clue as to what the standard of compliance with USPAP is! Read her example carefully…the ‘culprit’ was found NOT IN VIOLATION of the core charge of overstating the value. It brings into doubt whether any of the other allegations were as stated as well. Or, were they more prosecutorial sophistry?

      It says it is a nationally chartered organization but doesn’t say who they are chartered by or in what form they exist. I have been told they are a private corporation, but their own website fails to state that, or where they are incorporated.

      Seems odd that an organization ostensibly founded by State Employees to lobby or advocate on behalf of state employees who would otherwise be prohibited from lobbying; especially outside of Congressional or even state legislator’s oversight, would conceal its own organizational composition and structure.

      HOW is this unofficial association causing policy or rules interpretation by regulators across the country that are contrary to the content & intent of USPAP? Under WHAT specific authority?

      Perhaps IRS can shed some light on them. Maybe ASC since they and TAF seem so bound at the hip to them.

      Reread the NCAB attorney’s presentation again. Opinion such as that used in appraisals is scoffed at. “Actual proof” or fact such as that subjectively ARGUED or claimed by professional prosecutors is seen as something superior in some inexplicable way.

      • Update…not actually hidden, just buried deep so that its not readily apparent. From their bylaws (an interesting read).

        ARTICLE IV Status The Association is a nonprofit corporation, in the state of Texas, directed by its own membership through it elected officers and directors.”

        WHY do states whose legislatures passed very specific laws concerning appraisers after due consideration and PUBLIC debate and vote of ELECTED representatives need to have their PAID STATE EMPLOYEES work off the clock and in unofficial capacity to conspire how to bypass or manipulate those laws passed by states?

  7. Avatar certresidential says:

    Attorney breakout
    Thirteen people were in attendance.

    “The group discussed the investigation of complaints and the use of a conditional dismissal to close a case. There was consensus that a complaint based solely on value should still be opened and investigated for USPAP violations, in accordance with Policy Statement 7. Alabama will not take a complaint based solely on an allegation that the value was too high or too low.

    The Complainant must also give some support for their allegation, such as providing other comparable sales or mention features of the subject property that were not properly analyzed in the report.”

    Can’t wait for the “inspector / data collector” driven 1004p and Hybrid complaints to start rolling in….


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Increased Regulatory Persecution of Appraisers

by Michael Ford time to read: 7 min