The level of detail and documentation for what "summarize" has never been spelled out in USPAP. The only reference the ASB has ever made to what a "summary" is was in AO-11 (not USPAP proper), which just got retired in 2020 after being an AO for 25 years. And that example shows a paragraph for a summary of an analysis instead of an entire page for a description of that analysis as those terms have been used in SR2. There is no current reference which points to "summary" universally meaning 5 pages of charts and graphs to
describe everything the appraiser did to develop those adjustment factors, which factors themselves are also not referenced anywhere in SR1-4.a nor in SR2-2.*viii.
USPAP says what it says, and as is repeatedly reiterated in the Instructor's course, USPAP doesn't say what it doesn't say; and it's important for appraisers to refrain from reading more into the text than is actually present. Or for instructors to attribute to the text more than it actually says.
As an example, the appraisals I perform for many of my clients don't have the same user-driven requirements that *some* but not *all* residential lenders and users require. User-added "detailed descriptions" means user-driven which are crucial to the assignment in their own right and for exactly that "meaningful to the user" reason, but those user-driven add-ons are not universally applicable to all appraisal assignments. The minimum for a summary has always been far less than how "describe" was until-recently illustrated.
The GSEs have new reporting requirements coming online. Those new requirements are not universal across the entirety of appraisal practice. And as a reviewer, if a user's expectation hasn't been communicated to an appraiser then it becomes unreasonable to say that the quality of the appraiser's work was inadequate due to not meeting the known/knowable requirements of the assignment via the existence of the double secret uncommunicated expectation. The GSEs and other clients have an existing script and its important for reviewers to scrupulously stick to that script.
My point being: render unto USPAP only that which USPAP itself actually requires, and render unto the GSEs the additional requirements of their written policies which once stated also become a hard requirement. It appears TO ME that the specific violation you're citing is a violation of the GSEs policies, whereas if that same report went to a different lender outside those pipelines that user might have much lower expectations for summarizing that reasoning.
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