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And BTW, you are still ducking the question of what in USPAP you consider to be anti-appraiser. Instead of gaslighting the issue why don't you put some original thinking of your own into it?
 
It is nonsense and neuters the role of the appraiser as an INDEPENDENT opinion of value. How hard is that to understand? That's like thinking speeders should self-report. Or, the cook should dictate to the health inspector the temperature of the refrigerators and freezers. Or, let Tyson tell the USDA inspectors that they are wrong.

Completely agree. The moment the regulated party starts dictating terms to the independent evaluator, the system breaks down. Expecting appraisers to conform their opinions to GSE mandates while still claiming independence is contradictory at best.


Your analogies are spot on. We wouldn’t ask a restaurant to tell the health inspector what’s acceptable, or a driver to self-enforce speeding laws. So why are we pretending it makes sense for lenders or GSEs to shape the rules that appraisers must follow?


If the appraisal is supposed to be an independent opinion of value, then it needs to be treated—and protected—as such. Otherwise, we’re just validating what someone else already decided.
 
It is nonsense and neuters the role of the appraiser as an INDEPENDENT opinion of value. How hard is that to understand? That's like thinking speeders should self-report. Or, the cook should dictate to the health inspector the temperature of the refrigerators and freezers. Or, let Tyson tell the USDA inspectors that they are wrong.
Why? They're asking a question. If they're allowed to ask a question then how do you spin that into meaning they control the appraiser's response to that question? They're communiucating what they expect. No user is obliged to accept an appraiser's uninformed assumption of what that users will and won't expect in the SR1/SR2 workproduct which results.

They ask, we respond. Why do you object to that?

Edit to add: WRT to the "expect speeders to self-report" that's another consideration-free talking point. The PRIMARY mode of enforcement of any rule, law, regulation or other expectation is at the individual level - where the individual CHOOSES to comply with what they understand that requirement to be. Chooses to comply at the outset. As opposed to being punished into compliance after the fact, which is the most expensive and least timely and least effective mode of enforcement. Taking someone's license or throwing them in prison is the last resort which we reserve for the worst of the worst. Not the default.

Except in Arkansas, of course. They shoot appraisers for typos there.
 
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They're communiucating what they expect.
Plus every stip they ask and doing so to punish the appraiser who doesn't provide the "right" answer. Compare that to the conventional bank and the IAG... same as always. No updates ever couple months, no complex forms required. Only a couple of SOW requests - I have one bank that wants you to personally inspect... not much else beyond the IAG. And normally they either accept it or reject it. They rarely come back with pointless stips. If they feedback it is probably because they caught a real mistake.
 
USPAP was not written for the appraisers
it was developed after the S & L crash because the Fed's had no laws to hang over the unlicensed MAI and commercial appraisers who had been charged with inflating values. The Fed's realized they had lost most cases because there was no Uniform appraisal standards.

So USPAP is the Hammer to hit appraisers over the head with.

The GSE and Lenders form's and rule's disallowing traditional assumptions can make the appraisers violate USPAP.

Like in the legal World a Grand Jury can indict a Ham Sandwich. The USPAP in the hands of any Agency Looking to take you down will or can Cite USPAP Violations in any report done .There is no such thing as a USPAP compliant appraisal.
 
In my opinion USPAP should not be applied to GSE or Lender assignments where the agency and lender are creating their own assignment conditions. This is the trap the State Boards can use on the appraisers.

I remember arguing years ago with a big wigg at VA RLC that what he was asking us to do was a USPAP violation.

His response was, we are the Federal Government and we don't care, that's an appraisers problem, we're not regulated by USPAP so just do it .
 
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.
 
USPAP and NATO should both be ended . The country doesn't need either one.
 
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