George Hatch
Elite Member
- Joined
- Jan 15, 2002
- Professional Status
- Certified General Appraiser
- State
- California
First off, let me preface this by acknowledging that I am one of the 600. One of the first, as a matter of fact. I am an AQB Certified USPAP Instructor and one of the conditions I agree to in order to hold that cert is to be an advocate for USPAP and to support the party line when acting in that role. I am a cheerleader and if that means wearing the skirt and waving the pom-poms then so be it. I am not ashamed of my association with this endeavor nor do I see any reason to apologize for anything I've ever done whilst acting in that capacity.
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A number of our posters have expressed some dismay about the composition of the structure of The Appraisal Foundation, including its IAC. It's the kind of thing that typically ebbs and flows, but right now we seem to be at a high point. That being the case, I think a little dialogue on the subject may be appropriate.
Here is the Mission Statement of The Appraisal Foundation:
The Preamble in USPAP states that the role of appraisal standards is to protect the public trust in professional appraisal practice. The term "public trust" covers a lot of ground. Not only does it include the legitimate interests of our clients and their borrowers, and the interests of the federal government, but it also includes the legitimate interests of the intended users of appraisal services. And not just the banks.
If you'll take note of the 3rd bullet above, it states that one of TAFs missions is to disseminate information on appraisal standards and appraiser qualifications to pretty much everyone; and it specifically mentions industry groups.
In addition, The Appraisal Foundation solicits and accepts input from virtually anyone who is interested enough to send them something. They'll read anything an appraiser sends them, whether the submission is relevant to something they're working on or not.
For example, the current Preamble in USPAP is reportedly the result of an unsolicited submission from an individual appraiser. Apparently this appraiser thought they could make the Preamble flow a little better whilst retaining the concepts. The ASB wasn't even considering modifying the Preamble when they got it.
Not only do the AQB and ASB pay attention to the information that gets sent to them, they apparently take a somewhat active role in identifying areas where they can contribute to the reduction of confusion and controversy with respect to some of these issues. I would think it obvious to most of our regulars that probably close to half of the issues addressed in the monthly Q&As involve current or recent topics of discussion and controversy on a couple of the appraiser chat groups. I daresay that AppraisersForum.com may be the ASBs single biggest source of topics for their monthly Q&As, which in turn get assimilated into the ASBs Frequently Asked Questions publication.
While we're at it, I also think it's fair to say that when they're working on a topic the ASB considers in its deliberations many of the arguments, both for and against various stances, that appear here on this forum.
How does this relate to the IAC? Well, The Appraisal Foundation has established advisory groups for the purpose of soliciting input and disseminating information that focused toward specific perspectives to various interested parties. Industry is only one of those groups:
Appraiser Education. TAF also has a council for the appraisal instruction wonks at the various professional groups (ECAFS)
TAF has another council that's specific to interfacing with corresponding appraisal standards bodies throughout the world. The International Valuation Council (IVC):
TAF has another advisory council that's geared toward the interests of the various appraiser regulatory boards and agencies in the U.S., the State Regulator Advisory Group:
And lastly, TAF maintains the infamous Industry Advisory Council that is the main topic of discussion in this thread:
I suppose that if a group of appraisers wanted to sit in on those confabs and receive whatever other newsletters the IAC puts out we could pony up $2500 and join in. I think it would be a waste, though. If an appraiser wants to provide input and exert some influence on the ASBs deliberations it would be much easier and more direct to simply write them a letter.
The Aprpaisal Foundation also has a direct and formal relationship with the federal government via The Appraisal Subcommittee.
My point is that TAF has been structured to solicit input from all these various sources and to interface with these different interests on a level that's relevant to them. For instance, the state regulators probably don't have a lot of interest in international valuation standards topics, and vice versa. The industry groups probably don't have a lot of interest in the same things the appraisal educators do. If you could imagine assembling a dozen people from each of these interest groups in a single room and attempting to hold any kind of discussion it would probably turn into a meaningless mess in no time flat. Hence the value of running these focus groups.
If TAF didn't solicit or accept commentary from anyone and everyone it would be fair game for allegations of being unresponsive or ill-informed or obsolete. So herein lies the rock and the hard place for them.
The Appraisal Foundation is coming under fire on this forum by appraisers who have apparently been sleeping through their USPAP updates and are unable to make the connection between TAFs stated mission and the structure it would take in order to accomplish that mission. Some of you are apparently chagrined that TAF doesn't vet the membership on any of these councils without running them through an appraiser-approval process.
The other glaring sorespot in the argument that TAF has been bought and paid for by the corporate crooks is the complete lack of evidence in TAFs work; i.e., USPAP and the AQBs Appraiser Qualifications Criteria.
The verbiage in some of the Advisory Opinions and Q&As is sometimes a bit clumsy and sometimes the answers are phrased either too broadly or too narrowly to be considered meaningful by many readers. But those are not appraisal standards nor are they misrepresented by the ASB as being anything other than USPAP-based advice from the body that's responsible for the content of USPAP.
Speaking of which, the core elements of USPAP - Ethics and Competency - have not wavered since its inception. Indeed, most of the requirements in the Ethics Rule and the Competency Rule predate USPAP itself. They can be found in the various codes of conducts of the professional organizations, and prior to that, in some of the academic texts from the 1920s and 1930s. Some of these concepts, appraiser confidentiality being one of them, predate those authors as well.
My point is that I can see no evidence of the ASB, past or present, altering appraisal standards away from the underlying principles and concepts that have long governed our profession. Probably 98% of the changes the ASB has been making over the last 20 years have been geared toward cleaning up the verbiage and adding additional comments and explanations to the original version of USPAP. The primary exceptions to that include the big shift in 1994 to add the Complete/Limited and reporting labels to USPAP, the change in sales history reporting requirements for 1-4s, the replacement of the Departure Rule and associated references throughout USPAP with the Scope of Work Rule. The ASB was on track to develop an overriding rule for reporting that corresponds to the SOWR, but I haven't heard anything about that for a while.
So herein lies my challenge to the IAC conspiracy buffs. Show us what indications in USPAP, the AOs, the monthly Q&As or the FAQs or any other communication from the ASB that indicates that they've been more influenced by the "input" of any other group than they have been by the input they get from appraisers. Let's skip the guilt-by-association, the reading of facial expressions, the paranormal feelings and the Vulcan mind melds for now and stick to the ASBs actions. Show us something.
After all, if the ASB hasn't actually done anything to appraisal standards that favor the crooks then any allegations that the ASB is acting in their interests becomes latently unwarranted.
Let's see an example of a change to USPAP or the codes of conduct used by the professional orgs that preceded USPAP that favors the cause of any user to the exclusion of the public trust.
----------------
A number of our posters have expressed some dismay about the composition of the structure of The Appraisal Foundation, including its IAC. It's the kind of thing that typically ebbs and flows, but right now we seem to be at a high point. That being the case, I think a little dialogue on the subject may be appropriate.
Here is the Mission Statement of The Appraisal Foundation:
The Preamble in USPAP states that the role of appraisal standards is to protect the public trust in professional appraisal practice. The term "public trust" covers a lot of ground. Not only does it include the legitimate interests of our clients and their borrowers, and the interests of the federal government, but it also includes the legitimate interests of the intended users of appraisal services. And not just the banks.
If you'll take note of the 3rd bullet above, it states that one of TAFs missions is to disseminate information on appraisal standards and appraiser qualifications to pretty much everyone; and it specifically mentions industry groups.
In addition, The Appraisal Foundation solicits and accepts input from virtually anyone who is interested enough to send them something. They'll read anything an appraiser sends them, whether the submission is relevant to something they're working on or not.
For example, the current Preamble in USPAP is reportedly the result of an unsolicited submission from an individual appraiser. Apparently this appraiser thought they could make the Preamble flow a little better whilst retaining the concepts. The ASB wasn't even considering modifying the Preamble when they got it.
Not only do the AQB and ASB pay attention to the information that gets sent to them, they apparently take a somewhat active role in identifying areas where they can contribute to the reduction of confusion and controversy with respect to some of these issues. I would think it obvious to most of our regulars that probably close to half of the issues addressed in the monthly Q&As involve current or recent topics of discussion and controversy on a couple of the appraiser chat groups. I daresay that AppraisersForum.com may be the ASBs single biggest source of topics for their monthly Q&As, which in turn get assimilated into the ASBs Frequently Asked Questions publication.
While we're at it, I also think it's fair to say that when they're working on a topic the ASB considers in its deliberations many of the arguments, both for and against various stances, that appear here on this forum.
How does this relate to the IAC? Well, The Appraisal Foundation has established advisory groups for the purpose of soliciting input and disseminating information that focused toward specific perspectives to various interested parties. Industry is only one of those groups:
Appraiser Education. TAF also has a council for the appraisal instruction wonks at the various professional groups (ECAFS)
Now you know who to blame for the content of those USPAP updates you have to sit through.
TAF has another council that's specific to interfacing with corresponding appraisal standards bodies throughout the world. The International Valuation Council (IVC):
TAF has another advisory council that's geared toward the interests of the various appraiser regulatory boards and agencies in the U.S., the State Regulator Advisory Group:
And lastly, TAF maintains the infamous Industry Advisory Council that is the main topic of discussion in this thread:
From what I understand, virtually any company with a spare $2500 can join this advisory council. Zaio made it a point to join up and loudly trumpet their connection to The Appraisal Foundation like it was some kind of spectacular achievement; that obviously didn't help them out any.
I suppose that if a group of appraisers wanted to sit in on those confabs and receive whatever other newsletters the IAC puts out we could pony up $2500 and join in. I think it would be a waste, though. If an appraiser wants to provide input and exert some influence on the ASBs deliberations it would be much easier and more direct to simply write them a letter.
The Aprpaisal Foundation also has a direct and formal relationship with the federal government via The Appraisal Subcommittee.
My point is that TAF has been structured to solicit input from all these various sources and to interface with these different interests on a level that's relevant to them. For instance, the state regulators probably don't have a lot of interest in international valuation standards topics, and vice versa. The industry groups probably don't have a lot of interest in the same things the appraisal educators do. If you could imagine assembling a dozen people from each of these interest groups in a single room and attempting to hold any kind of discussion it would probably turn into a meaningless mess in no time flat. Hence the value of running these focus groups.
If TAF didn't solicit or accept commentary from anyone and everyone it would be fair game for allegations of being unresponsive or ill-informed or obsolete. So herein lies the rock and the hard place for them.
The Appraisal Foundation is coming under fire on this forum by appraisers who have apparently been sleeping through their USPAP updates and are unable to make the connection between TAFs stated mission and the structure it would take in order to accomplish that mission. Some of you are apparently chagrined that TAF doesn't vet the membership on any of these councils without running them through an appraiser-approval process.
The other glaring sorespot in the argument that TAF has been bought and paid for by the corporate crooks is the complete lack of evidence in TAFs work; i.e., USPAP and the AQBs Appraiser Qualifications Criteria.
The verbiage in some of the Advisory Opinions and Q&As is sometimes a bit clumsy and sometimes the answers are phrased either too broadly or too narrowly to be considered meaningful by many readers. But those are not appraisal standards nor are they misrepresented by the ASB as being anything other than USPAP-based advice from the body that's responsible for the content of USPAP.
Speaking of which, the core elements of USPAP - Ethics and Competency - have not wavered since its inception. Indeed, most of the requirements in the Ethics Rule and the Competency Rule predate USPAP itself. They can be found in the various codes of conducts of the professional organizations, and prior to that, in some of the academic texts from the 1920s and 1930s. Some of these concepts, appraiser confidentiality being one of them, predate those authors as well.
My point is that I can see no evidence of the ASB, past or present, altering appraisal standards away from the underlying principles and concepts that have long governed our profession. Probably 98% of the changes the ASB has been making over the last 20 years have been geared toward cleaning up the verbiage and adding additional comments and explanations to the original version of USPAP. The primary exceptions to that include the big shift in 1994 to add the Complete/Limited and reporting labels to USPAP, the change in sales history reporting requirements for 1-4s, the replacement of the Departure Rule and associated references throughout USPAP with the Scope of Work Rule. The ASB was on track to develop an overriding rule for reporting that corresponds to the SOWR, but I haven't heard anything about that for a while.
So herein lies my challenge to the IAC conspiracy buffs. Show us what indications in USPAP, the AOs, the monthly Q&As or the FAQs or any other communication from the ASB that indicates that they've been more influenced by the "input" of any other group than they have been by the input they get from appraisers. Let's skip the guilt-by-association, the reading of facial expressions, the paranormal feelings and the Vulcan mind melds for now and stick to the ASBs actions. Show us something.
After all, if the ASB hasn't actually done anything to appraisal standards that favor the crooks then any allegations that the ASB is acting in their interests becomes latently unwarranted.
Let's see an example of a change to USPAP or the codes of conduct used by the professional orgs that preceded USPAP that favors the cause of any user to the exclusion of the public trust.
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