USPAP Absurdity

USPAP Absurdity - Zero Value to Appraisers or the Public. From one of my appraiser colleagues in NYC on a McKissock class, taught by Dan Bradley, husband of Michelle Bradley who is chair of the Appraisal Standards Board of The Appraisal Foundation (this is COMPLETELY UNETHICAL). TAF BOT (the leadership that brought us the bat-shit crazy letter) is meeting in sunny Palm Springs San Diego right at this moment (probably to determine meanings of words like “The” and “This” and “That” and perhaps considering a new take on “misleading” that is still on the books!!!, of course, I realize that’s for the ASB to decide but please allow me some comic license here) so appraisers can do a better job at their craft. Don’t get me wrong, most of the BOT and who volunteer, are good people and mean well and some are trying to change from within, but it is a Bunton/David’s monarchy, period, and because of the lack of allowed new thinking, the organization lost its way long ago.

But I digress.

Back to what my colleague recently said:

I started the CT course and realized I’ve taken in the past. It’s absolutely ridiculous that we have to take this, let alone every two years. And it’s all videos so you have to let it play and keep moving to the next one. It’s best to listen in the background while you work on something else and then take the quizzes. The fact that this is mandatory is nothing more than a money grab. There is no new information at all.

Taking repetitive classes that do not either refresh memories or teach something new provides zero value to appraisers or the public. C’mon, this is not that hard to fix.

Combine this outrageous waste of time with the indoctrinated mantra of taking USPAP every two years when the updates (most are clerical and useless that we now know are only done to sell books and classes) could be taught in 15 minutes rather than seven hours. This is EXACTLY why I have been so critical of TAF over the past several years. I’ve had it. They are just doing this for the money to maintain financial independence (a stated and bizarre goal) and have lost their way. In actuality, appraisers have been abandoned by TAF and so has any concern about the public trust.

Jonathan Miller
Image credit flickr - Kendrick Hang
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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29 Responses

  1. Kimberly Pugh DeFilippis on Facebook Kimberly Pugh DeFilippis on Facebook says:


  2. Phillip Case on Facebook Phillip Case on Facebook says:

    I second that. Total waste of time.

  3. Rob Engle on Facebook Rob Engle on Facebook says:

    Useless Pap

  4. Rvs Simon on Facebook Rvs Simon on Facebook says:

    Ok I’ve taken the refresher 8 times and still the amount of information wouldn’t fill one 7 hour class. Every time, there’s always chatter about every 5 year class which would be more reasonable.

  5. Avatar Dana O'Hara Smith says:

    Agreed. 7 hours! It should take no longer than 2-3 hrs MAX.

  6. Debbie Lynn on Facebook Debbie Lynn on Facebook says:

    100exclamation pointexclamation point

  7. Avatar David says:

    The course I took very recently which was the usual look for extreme appraisal board sanctions to scare appraisers and not much else of any substance. But what really confirmed in my mind the instructor hypocrisy was the complete lack of interest in addressing how USPAP can’t even begin to allow desktop appraisals. I’ve been taking USPAP courses for 20 years or more and no amount of redefinition or rearranging the deck chairs it’s going to create THE collateral verification as a part of the appraisal process with desktop appraisals. This is some foolish idea that Fannie has and the entire lending industry is trying to embrace it despite the fact that only 20% of the appraiser surveyed said they’d do them. That aside with we are talking about USPAP and there is no way desktop appraisals even begin to comply with USPAP. Your thoughts please; please be specific.

  8. Baggins Baggins says:

    What many of the CE providers are doing these days is just re issuing the came class content, under a different class name. Why not, it’s what USPAP does. In the sales industry, they call that slam dunking every single customer, and everyone is required to be a customer, no opt outs.
    Check out the Industry Advisory Councils. Give you two guess why you do not feel fairly represented.

    Oh, wish I would not have even looked. It gets better. Here is their latest AVM task force report.
    How sweet, a uspap for avm’s, complete with certification and all. I wonder whom might get replaced. And no better company to rely on than Zillow, they really kept the markets running smoothly with the ibuyer approaches. That will be the top link, latest AF task force paper.

    Appraisal Data Ownership / All valuation products need good data. Appraisal data is generally thought of as the gold standard. The GSEs have been capturing appraisal data for years. However, they continue to refuse to release it to the industry. There is near unanimity by stakeholders that this data should be made available. The release of the GSE data to stakeholders will improve the accuracy of all valuations and build a foundation upon which AVM data scientists and statisticians can develop the testing and auditing tools required for broad adoption.

    Finally, we feel that any standards for AVM quality control would benefit from testing and evaluation by an independent third party. AVMs that were found to meet development and assessment standards would be eligible for certification analogous to how individual appraisers are licensed in particular property valuation domains. Designing the certification process will require a lot of thoughtful design as both the evolution of market conditions and the AVM models themselves could render past certification invalid and undermine the credibility of the AVM reviewer.

    Thoughtful designs, how considerate. Like being sure to license the company, not any of the individuals. Complete liability protection. And since they’ll be using GSE CU system data, they’ll become an interested party capable of suing appraisers, should any of the entered data turn out to be faulty. That appraisal data however, not for use by the appraisal industry, per Appraisal Foundation. Brilliance! From one bat shit crazy position to next. These people do not speak for individually licensed appraisers. Another co opted front group.

  9. Avatar Diana n says:

    Exactly what I have been saying for the last 20 years. It’s all about the money for them certainly not for us.

  10. Avatar Brian Jarrard says:


  11. Avatar Klara Lorinczi says:

    I have thus far refused to do any desktop 1004 appraisals but if I ever do, I will charge full fee for them. That way, they either order from me or not but I still make a decent living and they can ask themselves why they have gone that route if its not saving them money. If I still have the same liability, in fact more, then there’s no reason to reduce my fees. I agree that we should not have to retake USPAP classes every two years – that’s just silly. Every 5 years would be more reasonable and in the meantime, if there are any substantial changes, they can just publish them.

  12. Avatar Gordo says:

    If licensing solved all the appraisal problems, then why do we need USPAP or CE credits?

    Answer: It didn’t

  13. Theresa McReynolds on Facebook Theresa McReynolds on Facebook says:

    I totally agree with repetitive classes, I like a challenge. The appraisal institute offers a variety of classes that exceed basic classes.

  14. Rick Nielson on Facebook Rick Nielson on Facebook says:

    I’ve thought about sitting in the back and working in an appraisal or two during these.

    • Baggins Baggins says:

      In one class I literally watched an appraiser right in front of me down a foot or two in the auditorium type class with raised seating do just that. He had a tablet and click and auto fill through reports like lightning speed. Did not bother with any unique writing, just auto data import, generic prefill language, applied static adjustment basis, and was on to the next one. I think he completed about 4 appraisal write ups during a single uspap class. He was bragging about getting all the amc work. That is a true story.

  15. Avatar Johnny Q says:

    Well I recall some years back when they started making the clarification in USPAP that bold letters were added for emphasis. You don’t say, really?

    • Baggins Baggins says:

      When you’re constantly changing minutia for no good reason other than some one some where being possibly confused…. They don’t even bother to ask the appraiser if there may be dimensia issues, they just clarify and re write. How to CYA with the volunteer group.

  16. Avatar Honest Appraiser says:


  17. Avatar JUAN ZAMUDIO says:


  18. Avatar Elandy says:

    Agreed! Our industry has become a sham. I regret having gotten into this business. Every time I complete a survey after another redundant, BS class, they ask for comments/suggestions. My answer (like the class) is always the same – Give us something new. Give us something useful. SAD

    • Baggins Baggins says:

      It’s a similar situation why big corporate injection in public school merely results in more commercial exposure and less quality education. Training a future generation of subservient and compliant consumers. Conflicting motivations and conflicts of interest.

      Show me the appraiser CE class which specifically deals with actually reading all relevant legislative guidance. You’d get all your hours in a single class and would have only read one guidance document front to back. Or how about ethical billing practices as accepted in the larger business industry. Perhaps situational examples of how people take advantage of non profit status for exceptional profits. We simply can’t have a how to defend yourself from corrupt corporate business interests, or appraisers may wake up to what’s happening in front of their very eyes. Under no circumstances will we be learning about how government interjection makes things worse not better.

  19. Avatar Robert Livingston says:

    The desk top appraisals by a third party are totally Illegal. How can we depend on a third-party non-appraiser to judge and overlook the property? Answer per USPAP we can’t.

    How many times have we been told our trainee can’t see a property and they have been to the pre-appraiser classes and have been in training under our supervision? Yet now they want a non-appraiser to do inspections for us. We are also told to give them a room location. On top of that they don’t want to pay a reasonable fee (not that I would do one for any fee, if you do you may be kissing your license goodbye).

    Speaking of fees if you take what VA has been charging for fees and add for the last few years the cost of living then the fees should be just over $600 per appraisal of a typical property, not waterfront of complex in any fashion.

    So, if the board is allowing illegal appraisals how can they hold any appraiser to any other infractions or judgment against the appraiser? How can they keep telling us we must take the USPAP classes if they are condoning these illegal appraisals?

    I have pasted on a comment that came from VCAP in the state of Virginia, I have permission to share this:

    Desktop Appraisals

    Virginia Statutes and Regulations are very clear the appraiser who signs the appraisal report must have complete direction and control over the appraisal.

    As the Appraiser…
    54.1-2009 Definition of appraisal
    “Appraisal” means an analysis, opinion, or conclusion relating to the nature, quality, value, or utility of specified interests in, or aspects of, identified real estate or identified real property. An appraisal may be classified by subject matter into either a valuation or analysis. A “valuation” is an estimate of the value of real estate or real property. An “analysis” is a study of real estate or real property other than estimating value. The term “appraiser” or “appraisal” may be used only by a person licensed or certified by the Board.

    54.1-2011 Necessity for license
    C. Notwithstanding subsections A and B of this section, an individual who is not a licensed residential real estate appraiser, a certified residential real estate appraiser, or a certified general real estate appraiser may assist in the preparation of and sign an appraisal if:
    1. The assistant is under the direct supervision of a licensed residential real estate appraiser, a certified residential real estate appraiser, or a certified general real estate appraiser; and…

    18 VAC 130-20-180 Standards of professional practice.
    C. Use of signature and electronic transmission of report.
    1. The signing of an appraisal report or the transmittal of a report electronically shall indicate that the licensee has exercised complete direction and control over the appraisal. Therefore, no licensee shall sign or electronically transmit an appraisal which has been prepared by an unlicensed person unless such work was performed under the direction and supervision of the licensee in accordance with § 54.1-2011 of the Code of Virginia.

    And if you are an appraisal management company soliciting these products…
    18 VAC 130-30-160 Prohibited Acts
    The following acts are prohibited and any violation may result in disciplinary action by the board:
    1. Violating, inducing another to violate, or cooperating with others in violating any of the provisions of any of the regulations of the board or Chapter 20.2 (§ 54.1-2020 et seq.) of Title 54.1 of the Code of Virginia, or engaging in any acts enumerated in § 54.1-111 of the Code of Virginia.

    It is noted that the state of Maryland has warned appraiser that they are 100% responsible for all the information in their appraisal.

    • Baggins Baggins says:

      Related. Is that grounds to call the appraisal complaint hotline?

      Because one of the things the ASC does (per the lengthy regulations posted in the later half of their report), or is supposed to be doing, is assuring that individual amc’s are following state based rules for amc’s. Obviously they’re not looking at this, per the stark differences between complaints put towards appraisers vs complaints put towards amc’s. Because everyone knows, just redirect all complaints to appraisers. The difference there is a clear reflection of the way amc’s scoot all their problems to the appraisers. The lesson for appraisers; work with amc’s, increase your liability exposure.

  20. Avatar David says:

    Try this conspiracy theory.
    Desktops do away with collateral verification. AMC hires certified general appraiser. AMC and certified general appraiser apply for and get a license in your State under reciprocity and get it. Start doing appraisals at below market fees. And to add insult to injury attempt to hire a bunch of trainees in your market to put us all out of business what do you think of that? Buzz Feed is all encouraging the DESKTOPS in collaboration with the AMC’s swimming the waters like sharks!

  21. Avatar David says:

    The charge towards desktops is being led by Lyle Radke, Senior Director, Single-Family Collateral Risk for FANNIE. Might make sense to get to know him! He is unequivically in the AVM corner!

    • Baggins Baggins says:

      Lyle Radke. That was easy research.

      Radke sees a lot of opportunity to make valuations more reproducible. “A lot of appraisers will tell you that what they do is an art form. And what they mean by that, is that it’s hard for them to explain rigorously exactly what they’re doing. And I don’t mean that in a disparaging way, but it’s just, there’s a lot of experience and intuition that goes into it, right. A problem with that is it’s hard to reproduce. And it’s hard to critique,”

      Well… Great representation of the individual appraisers. Because there is no need for human interpretation of the subjective human decisions involved for all those buyers and sellers, corrupt to honest agents, lack of agency, lender pressure, amc middle management meddling and their pressures, etc, etc. What is going to bolster consumer protection is more automation. FNMA is in the business of protecting lenders. Protecting consumers and regular tax payers; not so much.


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USPAP Absurdity

by Jonathan Miller time to read: 2 min