hastalavista
Elite Member
- Joined
- May 16, 2005
- Professional Status
- Certified General Appraiser
- State
- California
Stephen-
I'm all for doing the restricted report and I agree that if banks want to order them rather than some other non-appraisal product, that's potential business for us.
I just cannot get past the USPAP requirement to identify the client. That identification appears "specific" to me (unlike "intended users, which can be identified by type).
And, while the inclusion of "affiliates" may not create the red flag for an appraisal assignment (although, arguably, it should) that is reported to the "Appraisal Report" standards, it does raise a red flag (with me) because the emphases when a Restricted Report is appropriate is focused on the client and the fact that the client is the only intended user (indeed, Restricted vs. Appraisal is all about reporting requirements).
Does the broad term "affiliates" appropriately identify the client for a Restricted Report? Given the emphasis on client-identification and limiting a restricted report to the identified client(s), "affiliates" doesn't meet the requirement as I apply it for my decision-making process.
IMO, allowing appraisers to complete evaluations to the IAG standards rather than the USPAP standards would eliminate technical issues like this while not affecting the credibility/reliability of the valuation.*
I should be clear: USPAP can apply; but for an Evaluation, SR-1 and SR-2 need not apply as the IAG sets the requirements for the development and reporting minimums.
I'm all for doing the restricted report and I agree that if banks want to order them rather than some other non-appraisal product, that's potential business for us.
I just cannot get past the USPAP requirement to identify the client. That identification appears "specific" to me (unlike "intended users, which can be identified by type).
And, while the inclusion of "affiliates" may not create the red flag for an appraisal assignment (although, arguably, it should) that is reported to the "Appraisal Report" standards, it does raise a red flag (with me) because the emphases when a Restricted Report is appropriate is focused on the client and the fact that the client is the only intended user (indeed, Restricted vs. Appraisal is all about reporting requirements).
Does the broad term "affiliates" appropriately identify the client for a Restricted Report? Given the emphasis on client-identification and limiting a restricted report to the identified client(s), "affiliates" doesn't meet the requirement as I apply it for my decision-making process.
IMO, allowing appraisers to complete evaluations to the IAG standards rather than the USPAP standards would eliminate technical issues like this while not affecting the credibility/reliability of the valuation.*
I should be clear: USPAP can apply; but for an Evaluation, SR-1 and SR-2 need not apply as the IAG sets the requirements for the development and reporting minimums.
