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Many conveniently forget that USPAP is interpreted differently across states. What qualifies as a violation in one state might be overlooked in another. That inconsistency, combined with pressure from GSEs and lenders to use forms and rules that disallow traditional assumptions or limit professional judgment, puts appraisers in a constant bind. We are expected to comply with USPAP while also following guidelines that often contradict its principles.


And you're right. If someone wants to find a USPAP violation in any report, they probably can. It's like the "ham sandwich" grand jury analogy. The framework is so open to interpretation and so broad in scope that it can be used as a weapon just as easily as a standard.


So while USPAP was created to improve appraisal integrity, in practice it is often used as a stick, especially when paired with ever-tightening GSE mandates that quietly erode the independence it is supposed to protect.
I agree. There is no zero-defect assumption when it comes to politically appointed part timers enforcing state law and regulation.

You don't seem to be sufficiently self-aware to realize the intellectual disconnect of your criticism that the state boards have operated differently (which is a competency issue) vs your constant complaining about TAFs programs for engaging with the state boards to train them on what is/isn't in USPAP. Have you ever considered picking a principled position and just maintaining some consistency? Because if not, you should.

With that said, "is interpreted differently" is an act that people perform, and applies equally to the law/regulation these boards operate under. Some of them get that wrong, too. That doesn't mean fair and just and competent enforcement is impossible. It only means people sometimes make mistakes.

If there is even one state that is operating within specs then that example stands as proof of concept.
 
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I believe most can agree USPAP is a cluster F from day one. The problem is nobody's willing to change it or throw it out and start over.

Starting with their should be a USPAP written for GSEs and Lender's that make them create Assignment Conditions that are USPAP compliant. Even Pre Printed GSE Certs in some cases, cause USPAP Violations.
 
I like USPAP. I get the intent of the standards.
 
if USPAP wasn't meant for the appraiser...then why do we need the class :rof:
 
Fine - "It's a CF from day one"

Which triggers the obvious follow-on question: compared to what?
  • Compared to 55 individual standards at the state level, each (actually) worded and (actually) intended - usually by incompetents - differently from one another?
  • Compared to deferring to the same GSEs that get accused every day on this forum of engaging in anti-appraiser conduct?
  • Compared to deferring to the same Appraisal Institute that gets criticized as being corrupt?

Compared to what alternative? That's a question the belligerents never seem to want to engage with. Too busy throwing rocks to suggest what the better-for-everyone alternative might look like.

The fundamentals of what we refer to as the ETHICS RULE and the COMPETENCY RULE existed in this business long before the inception of USPAP and will continue after USPAP is replaced by whatever comes next. But I guarantee what the level of belligerence and opposition will continue unabated because no matter what, these guys always interpret appraisal standards as being strictly punitive in nature. Not as a defensible standard of conduct.
 
GSE guidelines are problematic.

There is no target date but the end goal is no appraisals for GSE originations. Possibly no appraisals for all mortgage originations. So we all have to plan accordingly depending on individual circumstances. That is about all we can do.
 
if USPAP wasn't meant for the appraiser...then why do we need the class :rof:
The terms and conditions of your license require your compliance therewith; to which you agreed in advance prior to obtaining that license. And because the state cannot prove that you were exposed to the material and are responsible for that compliance without some structure which requires that exposure.

Appraising for these transactions is not a right. It's a privilege.
 
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