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  #1  
Old 08-29-2009, 10:50 AM
Mike Kennedy's Avatar
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Exclamation ASB Request for comments on USPAP Reporting Requirements Aug 2009

Request for Comments or Suggestions on USPAP Reporting Requirements

Issued on August 28, 2009. Comments requested by October 31, 2009.

Public comments are also invited at the ASB public meeting on September 11, 2009, in Seattle, Washington. Information on this meeting is also available on the Appraisal Foundation website.
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  #2  
Old 08-29-2009, 12:22 PM
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My comment is simple. Ban anyone but FHA from creating or requiring "forms" and let appraisers write reports that are appropriate for the occasion...not dictated by fannie mae, nor anyone else. "Summary" "self-contained" and "restricted" need abolished as terminology.
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  #3  
Old 08-29-2009, 06:36 PM
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Coming soon to a USPAP near you: RURs for lenders. Just a guess.
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Old 08-29-2009, 08:03 PM
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All reports are summary. How about some banks being under these rules? Why are they only for appraisers? In order for them to make sense, make the lender just as liable as we are

You know what? This is kind of crazy when the banks control everything. Did the pusses check to make sure the banks agree? Silly

Quote:
Originally Posted by Terrel L. Shields View Post
My comment is simple. Ban anyone but FHA from creating or requiring "forms" and let appraisers write reports that are appropriate for the occasion...not dictated by fannie mae, nor anyone else. "Summary" "self-contained" and "restricted" need abolished as terminology.

Last edited by fifteen : 08-29-2009 at 08:10 PM.
  #5  
Old 08-29-2009, 08:32 PM
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The last part in there about "Draft Reports" code for "Comp Checks". It's an interesting read and one should pay attention too. I think that if they allow the term "Draft Report", it allows a very watered down report aka "comp check report" or quick and dirty report. This has nothing to do with the appraisal practice, it's about entertaining the AMC's and others that want this so called "Product"...........Who else calls our work "products" anyways?................(I wish they would stop calling it a product, it's An Appraiser's Propriety Business Information). They are trying to slip it in, because its a "concern" of certain complex assignments. I think it's a Trojan Horse.

Last edited by Workbox : 08-29-2009 at 08:44 PM.
  #6  
Old 08-29-2009, 08:52 PM
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Originally Posted by Caligirl View Post
Coming soon to a USPAP near you: RURs for lenders. Just a guess.

What do you mean "coming soon"? There is nothing that prevents an appraiser from doing a RUAR for a lender now. In fact, I did one for a lender this week.
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  #7  
Old 08-29-2009, 08:56 PM
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Mr Wiley ... with all due respect, I personally dont see a reason the ASB asks for comments other than to give lip service to the appraisal community. They dont listen to a damn thing anyone says ... thus we have USPAP 2010 - 2011 .... with some absolutely horrible provisions in it ... most against the wishes of appraisers.

I say just make the damn rules and tell me what I have to do .. but dont insult me and ask for my opinion ... they dont care.
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  #8  
Old 08-29-2009, 09:07 PM
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Quote:
Originally Posted by Workbox View Post
The last part in there about "Draft Reports" code for "Comp Checks". It's an interesting read and one should pay attention too.
"Draft" is not code for "comp check." Most residential appraisers don't use "drafts" on a regular basis, but "draft" reports are very common in many facets of the appraisal profession e.g business valuation, litigation, mediation. This issue is troublesome for many, and cleaning it up would be a great service.

The paper starts by addressing details and then moves on to talk about fundamentals. IMO, if they want to be successful, they need to consider things in the opposite order. And they should encourage respondents to do the same.

First, the ASB should establish what USPAP should say about appraisers' communications. Communication is more fundamental than reporting.

Only after tackling that should they move on and look at the basic definition of "report."

After doing that they can start thinking about some of the details. If they start trying to handle the details before they sort out the fundamental concepts, they will soon find themselves in an unescapable maze of contradiction.

The current reporting standards were developed 20 years ago in a world without electronic reports. Some of the current rules don't even really make sense when talking about a report in an electronic format. It is good that this project has been taken back of the shelf, but doing it properly requires a very diligent and thoughtful review, not a knee-jerk reaction to anybody's pet peeves.

At the very least something needs to be done about the dependence of the reporting rules on the very artificial distinctions made in USPAP between "state," "summarize," and "describe." The differences attributed to these words in USPAP occur nowhere else.

The dictionary I use defines "decsribe" as

Quote:
to tell or depict in written or spoken words
Nothing about this definition implies that "describing" something means providing more detail that "stating" something.
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  #9  
Old 08-29-2009, 09:16 PM
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Quote:
Originally Posted by PropertyEconomics View Post
They dont listen to a damn thing anyone says ....
The responsiveness of the ASB to written comments depends entirely on the members serving at any given time. Some ASB members have given thoughtful consideration to all comments submitted. Some have not.
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  #10  
Old 08-29-2009, 09:16 PM
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Quote:
Originally Posted by DWiley View Post
What do you mean "coming soon"? There is nothing that prevents an appraiser from doing a RUAR for a lender now. In fact, I did one for a lender this week.
As a commercial appraiser I can honestly say I have never handed a lender a RUR. But I have a distinct feeling those days are over.
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