Bert,
I remember swapping posts with you way back about regression. I enjoyed that because you may be the only one on here I can learn something from. The MARS software was a great find, and I have your PPT presnetation.
I have been criticizing the work of the ASB on here for 8 years, and no one threatened my membership. Ambiguity is a problem in USPAP. I can't think of how that has been improved lately. Ambiguity starts with the definition of appraisal which refers to both a process and a result. That obligates the authors to use qualifiers every time they use the word appraisal appears for readers to know whether the reference is to process, result or both.
In response to the ASB questionaire from January, I gave an extensive answer about the best and worst parts of USPAP. I pointed out that the section with the ethical provisions of USPAP is the better part. There is little there that could be tweaked, although there are canons that one could consider adding (conflict of interest comes to mind). I pointed that the signficant problems are in the part that deals with performance.
Most of the individual problems in USPAP are in the lower-lever rules, IMO.
- First off, USPAP has contained the phrase "common basis of all practice" for quite a while. The idea of "specific requirements" that only go to specific situations is, on its face, in contradication with the idea of "basis of all practice." Thus the idea of deleting say, SR 1-4, in its entirety, suggests itself.
- Second, almost all of the really bad errors are in SR 1-4. Some of it is inscrutable and some of it is just erroneous. For example, in the income approach requirement, it says one must estimate expenses. That assumes there is only net income capitalization. That means every time anyone used GRM's, they were in violation. Further, SR 1-1a "correctly employ recognized methods" already covers dealing with expenses when necessary. One can critique vritually every one of these specific requirements in SR 1-4 for including false assumptions, bad language verging on inchoherence, and lack of necessity.
- Also at a "low" rule level, there is SMT-3. I am not sure there is any need to establish a uniform standard there. I believe the language of the rule contradicts the ASB's intent and the idea of (apparently) requiring the use of certain verb tenses is silly.
- Finally, Std 3 is a disaster (and the opinions about AVMs are loopy).
The loopy opinion on AVM's cycles me back to the original topic, BPOs. In terms of the part of the USPAP defintiion that states an appraisal is a result, an opinion, it is hard for me to see how it makes any difference whether the person developing it was assisted by a computer or calls it a BPO.
