Real estate appraisers are being charged with "Tech. Violations" of USPAP resulting from the lack of knowledge/understanding pertaining to FRTs.
http://www.appraisalfoundation.org/html/US...statement10.htm
THE STATEMENT (SMT-10)
This Statement provides appraisers, users of appraisal services, and enforcement bodies with clarification, interpretation, explanation, and elaboration to reaffirm an appraiser’s USPAP obligations when performing an assignment for use by a federally insured depository institution in a federally related transaction.
The requirements in this Statement apply and are binding when the purpose of an assignment includes developing an opinion of market value of real property for intended use by a federally insured depository institution in a federally related transaction.
ASB Response to the Issue
Each ASB response on how USPAP applies to a specific concern appears in italics followed by references to USPAP and guidance material in the Advisory Opinions section.
When the agencies’ appraisal regulations and guidelines supplement USPAP requirements, this Statement notes the agencies’ appraisal regulations or guidelines as SUPPLEMENTAL STANDARDS. The ASB’s statements about compliance with those requirements are in the context of the appraiser’s obligation to comply with the ETHICS RULE or COMPETENCY RULE , as applicable.
Given the scope of this Statement, a Table of Contents is provided.
THE ISSUE (SMT-10)
Federal financial institution regulatory agencies (agencies) have experience that indicate some appraisers are not following Uniform Standards of Professional Appraisal Practice (USPAP) and, when applicable, the agencies’ appraisal regulations61 and guidelines62 issued by the Federal Deposit Insurance Corporation (FDIC), Federal Reserve Board (FRB), Office of the Comptroller of the Currency (OCC), and Office of Thrift Supervision (OTS). This is particularly true in appraisals of commercial real estate and residential tract development projects. The agencies’ concerns involve three general appraisal areas: USPAP compliance, appraiser independence and appraisal review.
Federally insured depository institutions recognize that the agencies’ appraisal regulations and guidelines include the requirement that appraisals comply with USPAP in a federally related transaction.
Most appraisers recognize that the agencies’ appraisal regulations and guidelines supplement the USPAP requirements when an intended user of the assignment results is a federally insured depository institution for a federally related transaction. However, some appraisers are uncertain as to:
§ What does USPAP require when the intended user of assignment results is a federally insured depository institution and the intended use is in a federally related transaction, and
§ how do the agencies’ appraisal regulations and guidelines, which include supplemental standards, affect the appraiser’s scope of work and report content requirements?
http://www.appraisalfoundation.org/html/US...statement10.htm
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