At or During?
“At the time of assignment” refers to the time period commencing…
Last month, the Appraisal Standards Board (ASB) provided the ‘first draft’ of the proposed changes to the 2020-21 USPAP, which I circulated.
One of the points they mentioned is a goal to make USPAP easier to read and more understandable. OK, commendable.
Then on June 27, 2018, the Appraisal Foundation and the ASB released the latest USPAP Q&A “suggestions.” (The USPAP Q&A’s, AO’s, and FAQ’s are not directives, or even a ‘legal’ part of USPAP. Instead, they offer independent commentary on how a particular issue could be handled or solved, but may not be the only way.) See the PDF below.
Wouldn’t you know, the very first question in this Q&A had to do with how to interpret a certain phrase used in USPAP – which may not be easily understood.
Before you read my comment below, you might want to read this question and response a couple of times, perhaps out loud, which tends to imprint on the brain better.
The phrase “at the time of assignment” is used in a number of places in USPAP. Does this only mean at the very beginning of the engagement process, or can it refer to other times during the development of the assignment results?
“At the time of assignment” refers to the time period commencing with the appraiser’s agreement to perform a valuation service and ending with the completion of the assignment.
OK… the “time” period starts ‘now’ and ‘ends’ at some point later. Things happen with the assignment during those two time periods – which is what the Response means – not at a singular ‘time’.
Wouldn’t the phrase in USPAP “at the time of assignment” be better expressed by saying ‘during the time of assignment’? Or perhaps just a tad bit simpler: ‘during the assignment’?
You decide. And if you agree the USPAP wording could be simplified, send your written response directly to the ASB:
Appraisal Standards Board
The Appraisal Foundation
1155 15th Street, NW, Suite 1111
Washington, DC 20005
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“At the time of assignment” refers to the time period commencing…refers to the period of when the appraiser gets up from his chair and retires from the profession forever
And they are still playing with the verbiage.
It should say “upon engagement” is when your time starts. “At the time of assignment” could mean the minute you receive a request to bid an appraisal, because you have been ‘assigned” an ‘assignment” from a potential client.
Too many interested parties with their fingers in the cookie jar.
“One of the points they mentioned is a goal to make USPAP easier to read and more understandable”
Seriously? Y’all should be very proud of me. I resisted telling them specifically how to make it easier to understand.
“At the time of assignment” or at the time of the assignment could mean one of the two following”:
1. When an order was assigned to me.
2. ANY TIME during the process of completing that order.
Clearly they are now parsing far beyond common use and intent. TAF is looking for a legal distinction whereas you and I are typically referring to: (A) when an order was assigned (not necessarily legally the same as when it was accepted); (B) When we accepted it but not before that acceptance, or (C) The period from when I accepted the order until I delivered the appraisal ordered. The definition will be related to the context it is used in. Much like appraisal and appraisal. *g*
The problem is TAF cannot mandate how other people speak English. The lender considers the assignment time when they placed the order with the AMC; the AMC considers it when they first offered it to me. I dont count it as assigned UNTIL IT IS PAID FOR! Others may consider it assigned when they accept it. A lawyer and a court may conclude it to be something completely different; covering not only the actual period it is being worked on but an unspecified period before, or after that.
It is NOT up to TAF to teach us how to speak English.
If they really want to make USPAP easier to understand, then stop screwing around with it frivolously! I lose more respect for them on a daily basis.
Just STOP it! Now.
Wait until they want your files for assignments that were cancelled. And the ones you researched the subject before you decided to bid or accept, or even reply to.
Dying ain’t much of a living now is it