• Welcome to AppraisersForum.com, the premier online  community for the discussion of real estate appraisal. Register a free account to be able to post and unlock additional forums and features.

GSEs vs USPAP?

Mejappz

Elite Member
Joined
Dec 16, 2005
Professional Status
Certified Residential Appraiser
State
Florida
Two corrupt and clueless entities in need of elimination.

Recent GSE (Fannie Mae and Freddie Mac) guidelines for appraisers and lenders make some assumptions. In particular we can use, for example, the requirements for market analysis and time adjustments.

USPAP (Uniform Standards of Professional Practice) Rule 1-4 states that an appraiser must “collect, verify, and analyze all information…and must analyze such comparable sales data as are available.” [Emphases added]. Nowhere does USPAP say use the best 3 or 4.

In short, an appraiser must use all relevant data. The key words are: all and relevant.

And the GSEs? The entire large set of guidelines make quite the contrary statement. The GSEs claim they cannot require a particular method. However, they fall back to historical, outmoded methods based on the “Pick comps, make adjustments” paradigm. (On the other hand, the modern, evidence-based approach provides superior accuracy and precision, and can even be made to measure reliability/risk on individual appraisals.)

We can note in their (GSE’s) defense, that the “pick comps, make adjustments” paradigm continues to be the “established practice” in education promoted by the professional organizations (such as the Appraisal Institute), as enforced by the state regulatory agencies.

Even this assumption of using 3 comps – is embedded in the FannieMae Selling Guide. In the section entitled “Minimum Number of Comparable Sales,” the required minimum is “three closed comparables must be reported.” “The subject property can be used as a fourth comparable…”

These statements do not preclude the appraiser’s use of more sales. But these statements do not positively encourage the analysis of “all comparable sales data as are available” – as required in USPAP.

A following section states a controlling “should”: use closed sales within the past 12 months. What is ignored (if we apply modern data science methods) is that, properly done, market-analyzed time adjustments are highly reliable, and can present otherwise much more similar sales.

To sum up: The USPAP development standard requires the use of all available relevant sales, but qualifies it by “worthy of belief” (credibility). It does not mention the need for reliability or accuracy.

GSE guidelines, however, do ask for reliability and accuracy. Maximum reliability and accuracy require the use of all available relevant information. Unfortunately, the GSE guidelines are built on the outdated paradigm of “pick comps, make adjustments.”

The answer? Evidence Based Valuation (EBV)©. EBV is based on simple data science principles:

  • Include all relevant data (the “population”).
  • Apply the three basic predictive (adjustment) algorithms.
  • Measure or estimate reliability, using repeatable methods.
  • Deliver more than a point-value opinion.
Judgment, knowledge, and skills do not go away. The new needed judgment and skills are just different.
Market Price Indexing (MPI)© as taught by Valuemetrics.info, does not require specialized software. Existing spreadsheets or analytic software such as R (free open source) can be learned. Once understood, reliable and presentable graphs and results can be done in minutes or seconds.

However, appraiser skills and knowledge are needed. Judgment is still required.

The needed complete data judgment, and software are available in free webinars GeorgeDell.com/free-stuff. Or in the complete introductory class Stats, Graphs, and Data Science 1 CE class.

Graduates of a recent SGDS1 class can join us in the CAA (Community of Asset Analysts).


https://georgedell.com/a-USPAP-vers...l&utm_source=linkedin.com&utm_campaign=buffer
 
USPAP (Uniform Standards of Professional Practice) Rule 1-4 states that an appraiser must “collect, verify, and analyze all information…and must analyze such comparable sales data as are available.” [Emphases added]. Nowhere does USPAP say use the best 3 or 4.

In short, an appraiser must use all relevant data. The key words are: all and relevant.
That conclusion does not match the manner and context in which these requirements are actually framed in SR1-4

1732392311485.png

The 2-part test for SOW decisions remains unchanged. Regardless of what anyone wants to sell to appraisers.

1732392400137.png

Same with credibility - that's not judged on a fixed/immovable external benchmark, either. Nor is the reference to "all" evidence.
1732394225231.png

It appears the conclusion pits the test in the SOWR against the unqualified "all" with no exceptions being implied by the conclusion stated in the OP. Moreover, WRT appraising across the entire spectrum of real property appraisal practice in all market segments across the U.S., the unqualified "all" is nowhere near possible as an appraisal standard. There's a lot more to appraisal practice than pumping out 1004s in a residential subdivision. Apart from that specialty niche, too-small-to-quant datasets are the norm in many assignments.
 
Last edited:
Find a Real Estate Appraiser - Enter Zip Code

Copyright © 2000-, AppraisersForum.com, All Rights Reserved
AppraisersForum.com is proudly hosted by the folks at
AppraiserSites.com
Back
Top