Reason Why USPAP Was Extended

USPAP one year extension

What is the actual reason USPAP was extended without warning for an additional year? Don’t get me wrong. I am all for longer USPAP cycles or doing updates on an as-needed basis in an industry that changes very little. As I’ve mentioned before, Dave Bunton of TAF said during the ASB public call on February 19th that USPAP was extended another year because of COVID – yet that makes no sense. Zoom calls are ubiquitous these days, so COVID is not a legitimate reason – we can argue that TAF is MORE efficient with Zoom. I bring this up specifically because there doesn’t seem to be any supporting research or rationale behind this industry-impacting decision as we anticipate the looming chaos on the state legislative level.

The Fourth Exposure Draft of Proposed Changes for the 2022-23 USPAP and Comments provides significant evidence that the desperation for TAF to team up with AI after their bat-shit crazy letter to ASC made their alliance with AI necessary.

The Appraisal Institute presented an excellent summary on the flawed USPAP cycle in a letter dated February 3rd, a little more than two weeks before the February 19th ASB public event.

This suggests that Dave easily and hypocritically rolled over in his newfound weakness after more than a decade of bashing the Appraisal Institute for this very point.

And let’s talking about ‘misleading’ a little more.

More insights from that Appraisal Institute comment letter:

the Appraisal Institute does not agree with many of the proposed revisions and does not believe that the remaining proposed revisions in this Fourth Exposure Draft warrant the approval of a new edition of USPAP. The Appraisal Institute urges the ASB to consider extending the life of the current edition of USPAP for at least another year or until substantive revisions are exposed and adopted.

Extending the life of the current edition of USPAP would benefit appraisers, regulators, and the public trust. Extending the life of the current edition of USPAP would also allow the ASB to further consider such options as moving to a single reporting option that sets minimum reporting requirements.

And AI agrees that the insanely misleading “misleading” definition needs to be removed right now (bold my emphasis)…

The ASB proposes deleting the definition of “Misleading”: The Appraisal Institute agrees with this proposed change, however, the Appraisal Institute believes that quicker action may be warranted. In a previous comment letter, the Appraisal Institute stated that: The rationale notes that “Stakeholders expressed concern that a simple typographical error in a report could be viewed as misleading under the current definition” and that “the appraiser’s responsibility to avoid errors of both commission (intent) and omission (errors) are clear”. The Appraisal Institute sees no reason why such a potentially harmful term should be allowed to continue on to the next edition of USPAP and suggests that the ASB issue an appendix or bulletin removing this term immediately. Timely action on this matter would serve to promote and maintain public trust in appraisal practice.

Jonathan Miller
Image credit flickr - Tom Page
Jonathan Miller

Jonathan Miller

Jonathan Miller is President and CEO of Miller Samuel Inc., a real estate appraisal and consulting firm he co-founded in 1986. He is a state-certified real estate appraiser in New York and Connecticut, performing court testimony as an expert witness in various local, state and federal courts.

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1 Response

  1. One has to wonder.

    In this instance, I agree with AI re ‘misleading’. As VaCAP originally posted when the idiocy was first proposed. Also proposed AO16 revisions are problematic.

    TAF needs a larger picture discussion on the ongoing necessity of two-year cycled changes. It’s long past time to just leave PRINCIPLES alone. They dont require biannual window dressing.

    I’m all for refreshers on USPAP, but by leaving it alone for 4 to 6 years, more people will beging to memorize it again…as we used to. Putting it forward in our consciousness when we first accept assignments.


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Reason Why USPAP Was Extended

by Jonathan Miller time to read: 2 min