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From the Beginning - Who Decides?

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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.
 
BTW, Terrel's original question was about having a universally recognized and sanctioned body of knowledge. Obviously one doesn't yet exist, and obviously that deficiency is causing us a lot of problems. Offhand I'd say that's the next major goal we need to work for.
 
Heres one way to be one of the geezers with input:

Submitting Comments

If submitting written comments, we hope to have your comments by February 25, 2008, so that we can consider them at, and in advance, of our Los Angeles meeting. You may submit written comments by mail, e-mail or facsimile.



Mail:ASB/AQB ‘2008’ Invitation to Comment
c/o The Appraisal Foundation
1155 15th Street, NW, Suite 1111
Washington, DC 20005


E-mail:comments@appraisalfoundation.org

Facsimile:(202) 347-7727


Also, if you have any questions, please feel free to contact The Appraisal Foundation at (202) 347-7722.

 
George,

I cannot speak for Don-Lee-Mike or Rich but I'll just confirm your suspiciions that I do not earn that much from teaching USPAP. 2007 fees were precisely $1600- just got my 1099. I just do not keep track. Last year was my low record, however. But I do not think I ever went over about 6-7K from USPAP teaching fees.

I'll be doing the 1 day in February.

On the body of knowledge I agree it is sorely needed. If memory serves the AQB has that on their plate right now.

Brad
 
Inasmuch as appraisers are required to take the course every two years the math actually works out to just under $10m a year. A certain percentage of those students take their instruction via the distance education providers. The books were $30 each, student manuals cost money to print plus the royalties on those that are due to The Appraisal Foundation. Most schools have advertising, and administration costs, and meeting rooms to teach in have rental rates. The student fees aren't all net to the instructors, not even close.

If you want to talk dollars I'll do that. FTR, I've never netted more than about $10,000 in a year from teaching USPAP courses, and I probably teach it more often than about 90% of the other instructors out there. I'd be willing to bet that Don and Lee and Mike and Brad don't even do that much. Rich Heyn probably does better than that, but only because he owns his own school and he's constantly travelling (and more power to him for that).

You can make it sound like its all about the money if you want but the truth is I'd make more money if I devoted that time to doing more appraisals. Come to think of it, the time I spend on this forum sharing what I know about the subject with you guys positively dwarfs the amount of time I spend in a classroom setting and I guarantee you there's no money at all involved here.

I say all this by way of explaining that it really ain't the money, pal. And those are the sobering facts.

George,

Most of the teaching I do is through a local school. I do a few courses out of state. But, added all together I make somewhat less than you do teaching just USPAP. Probably about 40% of what you make, and that is on a 50/50 split with the school.

For the record, there are now just over 600 USPAP Instructors that are AQB Certified. Since all are not also state certified appraisers but teach in colleges or universities, they would not count. So probably about 500 is still a good number.

It is not a path to riches.
 
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.

Well said George, Thank you.

I find, more often than not, that the ones who complain the loudest about USPAP seldom read it, let alone try to understand what it means.
 
We could improve "understandability" but in doing so we'd probably degrade "enforecability".
George. How can I help but interpret that statement to mean exactly what it said? Or let me state the inverse. If we can keep USPAP less understandable, then we can aggressively enforce it. ..duh. If we can make it more understandable then you won't need to enforce it because the average appraiser can COMPLY WITH IT! You are making my point. USPAP is deliberately obtuse in order to be able to punish someone at will. No one can regularly comply with it, they can only think they comply with it, because some GURU will have to interpret it, perhaps with tarot cards or tea leaves.

So back to the THREAD. Who decides what is the great body of knowledge that we are supposed to 'know' or learn? We have opposing points in Appraisal Journal. Do we believe text books only from certain appraisal organizations? Do we only believe that which is presented in a juried professional Journal? What text book is my guidance to comply with Std 1-1a? If I cannot comply with Std. 1-1a then I cannot comply with any part of the document with confidence. So tell me what book to use. Look at the differences in say, 9th Ed and 12th Ed of Appraisal of Real Estate. The test ought be if the results are credible. It isn't. It's the journey, not the destination that is judged. So we do the great Journey and end up in Houston instead of Austin, but that's OK because we were told to go South from Dallas.
 
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Uh oh.

Methinks I am becoming a T.S fan.


Plus, his posts are shorter, and I am too uneducated and lazy to read the long ones that do all the explaining:rof:
 
According to the Appraisal Foundation there were approx. 560 USPAP instructors nationwide as of 2005 (I don't have the current number but I understand it's now lower due to the harder tests and the instructors fail rate - ouch). According to the ASC website there are 121,911 active appraisers nationwide (licensed, certified residential and certified general). Some states, like California also have trainees, so the total number of appraisers could be as much as 150,000.

Now given that an average USPAP course costs $130... just the teaching of the document is a nearly $20 million business in the U.S. That's almost $35,000 per instructor, not a bad salary.

These are sobering facts.
100,000 to 150,000 appraisers need USPAP every two years so every year 50,000 to 75,000 appraisers take USPAP.

50,000 to 75,000 divided by 25+/- attendees per class = 2,000 to 3,000 USPAP classes per year.

2,000 to 3,000 classes per year divided by 500 instructors = 4 to 6 gigs per instructor per year.

4 to 6 gigs per year at $750 to 1,250 net per gig = $3,000 to $7,500 per instructor.

Each class consumes 2-3 days given travel, prep, teaching and recovery.

Best case is $7,500 divided by 12 days = $625 per day divided by 8 hours = $78.13 per hour

Worst case is $3,000 divided by 12 days = $250 per day divided by 8 hours = $31.25 per hour

Average of the two = $54.69 per hour.
 
Who decides what is the great body of knowledge that we are supposed to 'know' or learn?

Clients
 
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