- Joined
- Jan 15, 2002
- Professional Status
- Certified General Appraiser
- State
- California
Yet judged by state boards. USPAP provides the minimum of what is "meaningful" to ALL intended users.
Yet judged by state boards. USPAP provides the minimum of what is required to be "credible" to ALL intended users.
Yet is judged by state boards, in relation to meeting the minimum USPAP requirements and not violating minimum USPAP requirements Standards and comments and not considering FAQs. Because FAQs are not enforceable as they are not USPAP.
Sorry, but the state board judges it all and enters the picture after loans default and lenders suddenly decide they were mislead and what was provided to them was not meaningful. Can we all say Chase at the same time?
USPAP is the external benchmark, and that benchmark is used by state boards to determine if the appraiser provided a meaningful and credible report, according to how the state board interprets USPAP, because let's face it. If the loan was made, the report must have been meaningful and credible, that's why the lenders have underwriters. So, what made all those reports not meaning and credible, 2007-today???
And if all this BS was correct, USPAP would not make the appraiser responsible for the appropriate scope of the work. USPAP would be a two sentence document, Do what the client tells you to do, and make a number that the client can use, solidifying your credibility.
.
You have an exceedingly poor understanding of how both USPAP and the state boards function.
USPAP holds the appraiser responsible for making the SOW decision and client extras can't drop below the minimums, but everything above what those minimums actually require amount to either client-specified extras or appraiser-specified extras that exceed those minimums.
And I LOL at your mischaracterization of client appraisal policies being equal to dictating predetermined value conclusions. Just because a lender asks the appraiser to consider/comment on the relevance of the 3 sales submitted in an ROV doesn't amount to telling the appraiser that they should return the subject's value at $352,000. And no amount of pretzel logic or your "read TILA" mantra is going to alter that fact or how that issue will be argued in front of a judge or any group other than beleaguered fee appraisers.
For the most part appraisers get into trouble on the competency side for not doing what they said they did. Telling lies, as opposed to simply making mistakes. If there is an appraisal problem, it's usually referenced in terms of USPAP, not independent of it. My state regulator has ALWAYS done that, and so have most of the other state boards that I've seen. As for USPAP being an external benchmark, if it's directly referenced by the regs as the minimum standard of conduct for licensees then that's all the integral it needs to be.
With the state boards, where there's a dispute as to the meaning of USPAP that has generally come down to a matter of competency with what the document actually does and doesn't say.
That's not to say that appraisers can ignore their state board's behavior, but unless you have recent examples of your state board penalizing appraisers for choosing inadequate SOW decisions (as opposed to not performing the SOW they claimed) involving inspections then I don't see what facts you have in support of an opinion that state boards are going to move the goalposts for assignments well beyond what the big power users and appraisers agreed upon.
Last edited: