- Joined
- Jan 15, 2002
- Professional Status
- Certified General Appraiser
- State
- California
There are two principal USPAP compliance issues with these HA’s:
Don’t let the salespeople and others promoting these HA products try to persuade you otherwise… just because you can do these in your bathrobe, bunny slippers, in your basement for $50-$75 a pop.
- the person acting as the ‘field inspector’ is actually performing Appraisal Practice as defined by USPAP. Some may dispute that statement. But without the field inspector’s inspection data, no actual Appraisal can be completed by the Appraiser – because the appraiser is not engaged as the ‘field inspector.’ It’s my guess that the majority of ‘field inspectors’ ARE NOT licensed appraisers. As such, an Appraiser who allows some unidentified person to perform Appraisal Practice in the preparation of a report is in violation of USPAP. (I know about an appraiser who had to forfeit his license back to the state for this very reason.)
- Having someone besides the licensed appraiser contribute Significant Appraisal Assistance, without identifying that individual in the report, is also a USPAP violation charged back to the appraiser who signed the report. Significant Appraisal Assistance is discussed in FAQ #248 in USPAP 2016-17. INSPECTING the subject property IS considered to be an action that provides Significant Appraisal Assistance.
http://appraisersblogs.com/subject-inspection-4-hybrid-appraisals
I would say that, in terms of concepts and principles, merely measuring and photographing are functions that non-appraisers can do and are not necessarily integral to the development of an opinion of value. And indeed, if an RE appraisal can be performed at the desktop - which it can - then that pretty much demonstrates the point that measuring and photographing is an optional step that need not be personally performed by the appraiser. Unless it's necessary as an assignment condition.
One control group for that assertion are the other appraisal disciplines. THEY aren't dependent on the appraiser personally developing the subject characteristics prior to analyses.
Even in RE appraising we have examples that belie the knee jerk chacterization of inspection is integral to appraising. One example is proposed construction - the appraiser isn't measuring, quantifying or photographing the improvements because they don't exist - except on plans and specs that were developed by someone else outside of the appraisal process. Another example are the retrospective value opinions where the improvements no longer exist. With some of those the RE appraisers are using subject info that they never touched.
Appraisal reviews where the review includes the reviewer's opinion of value - that reviewer is using information they never touched to develop their own opinions even if its agree/disagree with the value conclusion.
"Team" appraising where multiple appraisers are working on the same assignment are another example insofar as some of those appraisers are using subject info they never touched.
I know some of you wish there was no such thing as a desktop appraisal. But, that boat sailed a long time ago.
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