Category: USPAP

USPAP Confidentiality Questions... Can Using a Contractor Be a Violation? 7

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...

AGA Objects De Minimis Increase Proposal - It is Time to Call out the Liars 40

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...

Ulterior Motive in Raising De Minimus 20

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...

Skeptics, traditional, vocational or advanced appraiser. What kind are you? 31

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...

Automated Loan Processing to End Appraisers... 2019 Big Battles Ahead 18

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...

Report Observation & Trigger Points - Don't Fall Into a Trap! 10

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...

What Does it Mean Support and Prove? Uncertainty Is Risk 2

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...

Requests for Reconsiderations & Issues Surrounding these Requests 23

Requests for Reconsiderations

…appraisers continue to receive requests for reconsiderations on a daily basis. White Paper: Requests for Reconsiderations The paper states that one factor that complicates requests for revisions is that there are no consistent industrywide policies, guidelines, or forms related to this process. Furthermore, over recent years there have been changes in statute and policy with respect to appraiser independence obligations, which has resulted in some confusion among users of appraisal services (and appraisers) as to exactly what may be asked and provided in such requests. It is important to distinguish these requests from a request to make corrections or address...

What is Truth or Accuracy for Appraisers? How Do We Find Accuracy? 12

What is Truth or Accuracy for Appraisers?

Are we supposed to be paid truth-seekers? The appraiser is supposed to be accurate. What is “accurate”? Dictionary meanings say accuracy is “the condition or quality of being true, correct, or exact.” Tell the truth. Can it be? Hmmm. A search for truth. OK. So how do we come to know the truth? Are we supposed to be paid truth-seekers? Cool. I read that there are four ways to “know” truth: Tradition, Authority, Insistence, and Science. Wow! Let’s look at these briefly. This sounds serious! Let’s look at USPAP and The Appraisal of Real Estate. Appraisers have long been steeped in the...

Is It Possible to Prove an Adjustment 5

Is It Possible to “Prove” an Adjustment?

We read articles and advertisements on how to prove an adjustment. Is this possible? How wonderful it would be. To prove an adjustment, just push a button and bam! Out comes the correct answer. How could we have we missed this? …prove an adjustment, just push a button…Of course, if such a simplistic and exact answer was possible – anyone could push that button.  An AVM run, a BPO agent, an “evaluator”, or anyone else. Who needs all that USPAP competence and integrity stuff? Even a lender-appointed hybridized “field inspector” could just push the button. The whole process could even skip working with the licensed appraiser completely!...

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