Category: USPAP

Is SmartExchange a Problem & Resulting in USPAP Non-Compliance?

January 30, 2019

Is SmartExchange Not USPAP-Compliant?

Is Smartexchange Resulting in USPAP Non-Compliance? This blog is likely going to stir up controversy. It is likely going to have a few folks calling me a loyalist to a la mode, or other similar things. Am I a loyalist? I do not see myself as such, but a la mode has been the only software that I have used in my career for residential form reporting. I do use ACI in the corporate setting as a reviewer and manager in my firm. I like and consider many of the staff at a la mode to be my friends, and I have had long relationships...

a la mode / ACI / AI / Appraisal / Appraisal Institute / Appraisal News

Should We Raise the Appraisal Deminimus Threshold to $2 Million?

January 29, 2019

Should We Raise the Deminimus to $2 Million?

Bank regulators are nearing a decision to raise residential real estate transactions appraisal threshold to $400,000 from $250,000, for certain transactions. Perhaps it should be set to $2 Million, or $5 Million. It strikes me that we have two separate taxpayer regulatory/administrative/quasi-governmental organizations working in opposition. On one hand we have the Appraisal Subcommittee and The Appraisal Foundation (TAF), and 50+ state organizations attempting to regulate, license, and control the education of appraisers. USPAP, (Uniform Standards of Professional Practice) is promulgated by the Appraisal Standards Board (ASB) of the TAF. USPAP compliance is required for federally related transactions. USPAP comprises two parts:...

Appraisal / Appraisal News / Appraisers News / Uniform Standards of Professional Appraisal Practice / USPAP

Increased Regulatory Persecution of Real Estate Appraisers - USPAP

January 22, 2019

Increased Regulatory Persecution of Appraisers

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,...

AARO / AGA / AI / American Society of Appraisers / Appraisal / Appraisal Institute

USPAP Confidentiality Questions... Can Using a Contractor Be a Violation?

January 18, 2019

USPAP & Questions on Confidentiality

How can using such a contractor not be a violation? In the context of a real estate appraisal, especially a residential real estate appraisal for a lender thru an AMC, what is confidential? First, look at USPAP’s definition of confidential information (lines 105 – 108 in the 2018-2019 edition). It says “confidential information [is] information that is either…identified by the client as confidential when providing it to an appraiser and that is not available from any other source; or…classified as confidential or private by applicable law or regulation” (ibid; emphasis added). Notice confidentiality flows to the client, not to any...

Appraisal / Appraisal News / Appraisers News / Fannie Mae - Freddie Mac / Uniform Standards of Professional Appraisal Practice / USPAP

January 10, 2019

AGA Objects De Minimis Increase Proposal

We object to the proposal to increase the de minimis threshold at which no appraisal is required… Sirs: The American Guild of Appraisers (AGA), of the Office Professional Employees International Union (#44 OPEIU) of the AFL-CIO represents the members and extended family and retirees, taxpayer and consumer real estate appraisal interests of nearly Twelve and a half million citizens and voters. We object to the proposal to increase the de minimis threshold at which no appraisal is required from $250,000 to $400,000. Respectfully, if anything is done with it at all, lowering it to a range not to exceed $100,000...

AGA / AMC / Appraisal / Appraisal Management Companies / Appraisal News / Appraisal Organizations

January 8, 2019

Ulterior Motive in Raising De Minimus

…raising de minimus shenanigans being promoted… Appraisers, a couple of weeks ago, I sent out a message about a Fee/TT quote conversation I had with an AMC clerk. I received a number of responses from appraisers across this fruited plain who said often they will receive Fee/TT quote requests for the SAME property from MULTIPLE AMC’s. That corroborates stories I hear from appraisers I talk with at conferences. The entire AMC situation is a giant time-wasting game that really doesn’t benefit the borrower at all, and least of all, appraisers. Lenders are the coaches in this game. Another message I received...

AMC / Appraisal / Appraisal Management Companies / Appraisal News / Appraisers News / Trending

Skeptics, traditional, vocational or advanced appraiser. What kind are you?

January 4, 2019

What Kind of Appraiser Are You?

Skeptical skeptics are a rare breed. But growing in number… Different appraisers have different attitudes! Some have a lot of experience, others a lot of education. Others emphasize the ‘art’, while others consider themselves ‘quants’. Let’s put aside the ‘art’ versus ‘science’ discussion, where the artists say: “No computer will ever replace the appraiser”, or “No amount of education will ever replace experience”. The other side seems a bit confused. There are traditionalists. And there are the “advanced” appraisers. And there are the “vocational” appraisers, who don’t seem to care much about all of this. They just want to push through as many reports as possible. The skeptics tend to doubt...

AMC / Appraisal / Appraisal Management Companies / Appraisal News / Appraisers News / Uniform Standards of Professional Appraisal Practice

Automated Loan Processing to End Appraisers... 2019 Big Battles Ahead

December 28, 2018

Big Battles Ahead for Appraisers

…complete elimination of appraisal as part of their fully automated loan processing objectives… Our work as appraisers & appraisal issue advocates is certainly cut out for us all in 2019. I think appraisal unity is going to be needed if we are all to take on the adverse issues affecting us. That includes AI. They still have a large number of honest, & competent members. I think the rest of us will have to let AI take care of AI issues. I’m not averse to butting heads with them on specific issues when necessary but alienating them rather than seeking...

AARO / AGA / AI / Appraisal / Appraisal Institute / Appraisal News

December 17, 2018

Report Observation & Trigger Points

Appraisers, this is another essay written about a report I have ‘observed.’ I’ve mentioned before that I “come in contact with” appraisal reports from a variety of sources. Those that I determine have significant issues I write about. Conclusions about the ‘real value’ will be disclosed below. Trigger points for having reports formally reviewed are discussed. I do this because a majority of appraisers do not participate and interact with their peers on a consistent basis, and therefore may not get exposed to items that clients and lenders see in reports, which they question. I believe it’s important to expose items in reports that...

AMC / Appraisal / Appraisal Management Companies / Appraisal News / Appraisers News / Fannie Mae - Freddie Mac

What Does it Mean Support and Prove? Uncertainty Is Risk

December 13, 2018

What Does it Mean ‘Support & Prove’?

What we do is subject to uncertainty. I searched the words: support and prove in both USPAP and in The Appraisal of Real Estate”. Interestingly, the word prove is not found in either document in this context. The fuzzier word support is found throughout both. The word ‘support’ seems to support supporting your opinion. How is the word “support” used in the context of making adjustments? I decided the dictionary would provide some support for how the word ‘support’ is used. The results are curious, perhaps troubling. Which comes first: the opinion, or the analysis? Do you support your opinion, or do you come to a result from doing your analysis? As a verb, the meanings of ‘support’ include: suggest the truth...

Appraisal / Appraisal News / Appraisers News / Uniform Standards of Professional Appraisal Practice / USPAP