Ain’t No Way to Run a Railroad

USPAP Revisions Every Two Years... This Ain’t No Way to Run a RailroadAppraisers get frustrated with the constant changes and revisions every two years…

Folks, attached is the 1st Exposure Draft of changes to the NEXT “bible” of our industry. Read this over and then send in your comments per the instructions.

With this draft, the ASB is desiring to simplify much of the document to make it easier to read and understand. There are numerous proposed edits you’ll see when you read it. They explain their rationale for the changes. This is appreciated.

I’m also glad to see they have added to the Definitions the words “State” and “Summarize” which have not been easily understood, and either have not been explained or were buried somewhere within previous versions of USPAP.

While I tend to read USPAP for fun, but not so much profit, I and lots of other appraisers get frustrated with the constant changes and revisions every two years. This is partly due to the new members who rotate onto the Appraisal Standards Board regularly. Apparently the modus operandi is to give them something to do, and make them feel important, while they serve on that panel for several years.

But to be honest, it’s frustrating to have to sit through the update classes every two years, just because the previous version “ain’t good enough”, or so it seems.

Plus, it makes really teaching USPAP contextually to the huddled masses more difficult. Instead of learning this document deeply, we are forced to concentrate on the changes. Frankly, there is a huge disrespect and lack of understanding for this document among appraisers, even though appraisers are required to comply with everything in it. This “ain’t no way to run a railroad”, in my humble opinion.

USPAP should be kept in place for at least 4 years so it can properly season, and appraisers can get used to it, before new revisions are made.

Dave Towne
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Dave Towne

Dave Towne

AGA, MNAA, Accredited Green Appraiser - Licensed in WA State since 2003. Dave Towne on

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11 Responses

  1. Avatar Eric West says:

    Sad how often they can come up with thousands of regs for appraisers to follow but can’t find a way to protect appraisers against amcs extortions!

    • Retired Appraiser Retired Appraiser says:

      Great point Eric, notice how they are wasting no time in systematically destroying every part of Dodd Frank.  Also note that the only part that will remain untouched is the part that puts billions in profits each year into the pockets of banks (the AMC extortion part).  Cuomo created yet the opposing part is loving it.

  2. Avatar IMJSAYN says:

    Their slogan should be “making changes for the sake of changes”

    The only people benefiting from these minute changes are those making money from these puny changes

  3. Avatar Tommy says:

    Suggested changes relating to hybrid reports:

    Extraordinary Assumption (lines 640-644) has been modified to make it clear that an EA can be used about the reliability of an property inspection report.

    Inspections (lines 658-662) is added to the definitions to make it clear that an inspection means “in-person”. So one cannot inspect via photos or drones for example.

  4. Avatar Chris says:

    Its so they can make us buy over priced books…..!!!

  5. Mike Ford Mike Ford says:

    Don’t read the entire linked article again, but HERE is the real reason we get USPAP changed like clockwork. Being necessary for clarity or consistency doesn’t have, and never had anything to do with it.

    Just read the highlighted MISMO objectives or “collaborative Opportunities” in the following article (its an insert in the article-no further clicking required). If octopus is replaced by blank space, just click that open white spot)

    The TAF &FNMA answer to MISMO overall, though the driver (so I’m told by MISMO insiders) is the Mortgage Bankers Association.

    1. This is why we have UAD/ UCDP and CU

    2. THIS is why we had to be changed to ‘valuators’ from appraisers and USPAP tortured into a one size fits all guide

    3. This is why sound appraisal practices under a well thought out USPAP (Circa 1991-2000+-) had to be slowly rewritten to eliminate prohibitive standards and rules or modified to give MBA/MISMO greater leeway toward their BIASED objectives.

    4. Changes for greater clarity? OK, if they mean greater clarity for a computer to read, score and project results that would be honest. If they (TAF FNMA and/or MISMO) mean greater clarity for users including borrowers then that is a huge Pinocchio!

    5. The ‘system’ sought by MISMO is to degrade or erode confidence and reliability of traditional appraisals to a point where truly terrible alternatives that would never otherwise be considered, now suddenly seem ‘plausible’. Once there is ‘market acceptance’ (investor confidence as a result of a lot of multi tiered deceptions), then traditional appraising can be twisted into something represented by UAD/1004MC formats; NOW those that are known to be essentially garbage to begin with, can be morphed into Hybrids (which started as alternate standards appraisals) but which are now pure fantasy fabrications called ‘third party different scope of work appraisals‘ by their hucksters and defenders. The rest of us call them what they are…bullshit!

    It gets better. Re read the MISMO doc linked above. You see “hybrids” are only a temporarily intermediate plan. Adequate to destroy an entire profession, but not fast, reliable or cheap enough to be used forever.

    6. Next step is to get rid of all those pesky graphs and charts in COMMERCIAL work into a format that can be (1.) data scraped, and (2.) read by a computer and used as a basis for fully computerized automated valuations. For BOTH commercial and SFR appraisals.

    7. Then rid the process of hybrids AND appraisers, relying on the future full automated system.

    Preserving TRUST? I don’t think so. TAF didn’t preserve trust in USPAP itself, let alone the process of appraisal. USPAP is a joke to appraisers; too hard for state regulators to enforce properly (READ TAD WHITMER, MAI WorkingRE article on this!), something both lenders and AMCS never understood and never followed, and the general public thinks ZILLOW and Trulia or are “just as good”.

    Now, I know what my future career as an appraiser will be. It will be specializing in litigation suing parties that relied on automated data for valuations. Agents and sellers have already taught us how lucrative chasing those ambulances can be.

    For those that want to remain traditional, trusted appraisal professionals YOU NEED TO GET OFF YOUR HANDS AND DO SOMETHING! Before its too late. Either through the AI; ASA; others, State Coalitions, National Coalitions or the AGA, but DO SOMETHING!

    Even if its nothing more than each organization forming committees working with each other to investigate this and respond collectively.

    • Baggins Baggins says:

      Is it just me, or is there an unusually high quantity of ethics language strike out and replacement jargon in this latest installment of the lender directed ethics book for appraisers? It’s no longer an ethics book written for the benefit of appraisers and preserving the public trust. Like everything else big corporate touches, it’s been co opted. It does not matter though, the principals of checks and balances will remain in the hearts, minds, and financial decisions of wise Americans, regardless of the clever sales lines and product offerings of the day. Same old, same old, buyer beware. Now with automation so the process happens so instantaneously, buyers won’t have even a second to say no or reconsider.

    • Avatar don says:

      Appraisers have lost their creditability and their importance in the justice, security and insurance industries. Appraisers trying to shed liability and responsibility have lost their importance, to the the political bodies trying to gain their own importance. Several of those POLS have suffered reputation, but are still influencing and vying their skills.
      1994 ,1955 Seems like a long time ago when we petitioned to seek professionalism thru legislation, and when our organizations tried to gain importance thru corporate merging. Many of the appraisal clients of yesterday have ceased, been absorbed and our financial system has recently had major influence form alien nations. What influence can an American appraiser in a non free country.
      Get off Mikes hands and participate!

  6. Avatar Mee says:

    We decided to remove the word “the” on page 28, paragraph 3, sentence 2. This makes the sentence more clear. That will be $250 and 7 hours of your life please.

  7. Avatar Patrick says:

    My state requires education be completed by Fall of odd numbered years (ie Sept 30, 2019). Most appraisers will take their education class in the summer vacation of that year. They will be learning about the USPAP version (2018-2019) that is only good for another 3 months and then a new version comes out. The 2 year cycle is absurd. And most appraisers don’t even learn about it until it is expiring (in my state).


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Ain’t No Way to Run a Railroad

by Dave Towne time to read: 1 min