- Joined
- Jan 15, 2002
- Professional Status
- Certified General Appraiser
- State
- California
Amy,
"Lack of clarity" is a moving goalpost if ever I saw one. "Changed so often" is another. There have been two major changes to the requirements in USPAP and about 3 or 4 minor changes since its inception. Both of the major changes and half of the minor changes were made expressly for the purposes of making USPAP easier for appraisers to understand and comply.
Most of the other differences in USPAP 2008 vs USPAP 1989 consist of expanding and adding comments to material that was already there. In the original version, a single line in USPAP might reference 3 or 4 different criteria and not include any explanatory comments. As the years have gone by, each of those criteria get broken out into their own line and comments added to provide some context to readers, to better enable understanding and application.
The original version of USPAP didn't include the Statements on Standards and it ran 47 pages. Not counting the Statements, the front half of USPAP and SR1-10 now runs 77 pages. Virtually all of the added bulk is attributable to the addition of explanatory comments and breaking the multi-requirement lines into single requirement lines. And it was all done in the name of understandability and enforcability.
Speaking of which...
A lot of changes involve verbiage were made expressly for the purposes of enforcement, at the intended user, the regulatory, and the judicial levels. See, USPAP has never been just for appraisers. Unfortunately, the 9th grade reading comprehension level a lot of readers have sometimes has to give way to the use of verbiage that is enforceable, as in, leaving as few loopholes as possible.
The other hugely complicating factor is that USPAP is intended to apply to all areas of appraisal practice, not just to appraisers hacking out 1004 forms on tract homes for Fannie. That's why these minimum standards have to be conveyed in fairly broad terms - the ASB has to consider USPAP's application in all the myriad situations into which appraisers can get.
There is no doubt - the USPAP we have today represents a compromise on many fronts. We could improve "understandability" but in doing so we'd probably degrade "enforecability". We could improve on applicability for the SFR crowd but in so doing we'd render it useless for everyone else. We could make it more concise but in so doing it would be less detailed and more prone to selective interpretation. We could make it more detailed but then even fewer people would read it. We could leave it alone and not make any more changes but that leaves the existing problems in place and advances nothing.
No matter which way the ASB approaches it there will be criticism and indignation, and to some extent it will all be justified. Nevertheless, the ASB is charged with advancing the state of appraisal standards and must continue to meet the challenge of striking the compromise that does the least amount of damage.
I still say that the individual can do themselves a big favor just by reading the book. It ain't that confusing.
One more thing - if you guys want to complain about state regulators not understanding USPAP I suggest you recognize that not all of them are equally dumb or equally lazy. I suspect there are a good percentage of state appraisal board members who have actually read the book for content and have a reasonable understanding of what it does and doesn't say. If an individual has a comprehension problem, some responsibility for that problem should be attributed to the individual. The ASB shouldn't get blamed for the failings of individuals sitting on a state appraisal board.
"Lack of clarity" is a moving goalpost if ever I saw one. "Changed so often" is another. There have been two major changes to the requirements in USPAP and about 3 or 4 minor changes since its inception. Both of the major changes and half of the minor changes were made expressly for the purposes of making USPAP easier for appraisers to understand and comply.
Most of the other differences in USPAP 2008 vs USPAP 1989 consist of expanding and adding comments to material that was already there. In the original version, a single line in USPAP might reference 3 or 4 different criteria and not include any explanatory comments. As the years have gone by, each of those criteria get broken out into their own line and comments added to provide some context to readers, to better enable understanding and application.
The original version of USPAP didn't include the Statements on Standards and it ran 47 pages. Not counting the Statements, the front half of USPAP and SR1-10 now runs 77 pages. Virtually all of the added bulk is attributable to the addition of explanatory comments and breaking the multi-requirement lines into single requirement lines. And it was all done in the name of understandability and enforcability.
Speaking of which...
A lot of changes involve verbiage were made expressly for the purposes of enforcement, at the intended user, the regulatory, and the judicial levels. See, USPAP has never been just for appraisers. Unfortunately, the 9th grade reading comprehension level a lot of readers have sometimes has to give way to the use of verbiage that is enforceable, as in, leaving as few loopholes as possible.
The other hugely complicating factor is that USPAP is intended to apply to all areas of appraisal practice, not just to appraisers hacking out 1004 forms on tract homes for Fannie. That's why these minimum standards have to be conveyed in fairly broad terms - the ASB has to consider USPAP's application in all the myriad situations into which appraisers can get.
There is no doubt - the USPAP we have today represents a compromise on many fronts. We could improve "understandability" but in doing so we'd probably degrade "enforecability". We could improve on applicability for the SFR crowd but in so doing we'd render it useless for everyone else. We could make it more concise but in so doing it would be less detailed and more prone to selective interpretation. We could make it more detailed but then even fewer people would read it. We could leave it alone and not make any more changes but that leaves the existing problems in place and advances nothing.
No matter which way the ASB approaches it there will be criticism and indignation, and to some extent it will all be justified. Nevertheless, the ASB is charged with advancing the state of appraisal standards and must continue to meet the challenge of striking the compromise that does the least amount of damage.
I still say that the individual can do themselves a big favor just by reading the book. It ain't that confusing.
One more thing - if you guys want to complain about state regulators not understanding USPAP I suggest you recognize that not all of them are equally dumb or equally lazy. I suspect there are a good percentage of state appraisal board members who have actually read the book for content and have a reasonable understanding of what it does and doesn't say. If an individual has a comprehension problem, some responsibility for that problem should be attributed to the individual. The ASB shouldn't get blamed for the failings of individuals sitting on a state appraisal board.