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USPAP 2006 Online

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Steven,

I shouldn't need to point out to you that the different conclusions in the 3 examples are primarily attributable to the different levels of available information about the subject - it has nothing to do with appraiser laziness or wrongdoing and virtually everything to do with the different clients (and their designated users) deciding which level of diligence is sufficient for their needs. Because the client is an active participant in this decision process some level of responsibility for that decision rests with them. Even though their's is not the last word it is a consideration and we are required to include that consideration in our SOW decision.

As for the reviewer looking at all three workproducts, they would judge the credibility of each of the workproducts within the context of its SOW. There's absolutely nothing new about that, and when I say "nothing new" I'm going back before USPAP. There have always been examples of reviewers having additional information available to them that was not available to the original appraisers (#1 and #2 in these examples), such as more recent sales data that occurred after the effective date or a change in condition. It has never been appropriate for a reviewer to hold an appraiser accountable for information that could not have been available to them during the course of their assignment. That goes for directly comparing appraisals based on different assignment conditions (or different dates or different definitions of value, etc) as if they should be equal, too. Not appropriate then and not appropriate now.

You know, if I have to live with the things I've said in the past, so must the rest of the appraisal profession. I'll be the first person to admit that I've learned a lot about appraisal standards in the last few years and while we're at it, to credit some of that understanding to what I've learned from you. Hopefully I do have a better understanding of it now than I did in 1999 and hopefully I'll be farther along in 2010 than I am now.

The appraisal profession has never had an "accuracy" requirement as such, has never taken a binary correct-incorrect approach to value conclusions, and has always focused on the use of the data and methodology to judge between reasonable and unreasonable. We've never been able to point to only one universally recognized source to say "that is the one and only correct way to perform this valuation method". I can look at Akerson's teachings and see differences when compared to Ratliff's - did that make one or the other of them "wrong"?

IMO, your attempts to portray the ASB as breaking the faith is unfair because USPAP serves more than one role. Even if your way is the most correct way, having the most idealogically pure standards won't do us any good if we can't enforce them. And by "enforce" I'm not just referring to licensing. We have our hands full enough just dealing with our peers that won't adequately observe the requirements of "true and correct facts".
 
USPAP, the minimum standards: A no-inspection, ballpark-estimate

George,
IMO, your attempts to portray the ASB as breaking the faith is unfair because USPAP serves more than one role. Even if your way is the most correct way,
Let’s see if we can pry off this gremlin, the tactic of exaggerating the other person’s point and arguing against the exaggeration. I did not write anything to you about “correct way.”

We all understand that acceptable practice includes ballpark estimates for SWAG value based on no inspections. There is serious question as to whether a set of standards that does not intrinsically call for anything more than that is pointless.

I reject the idea that I put on any “unfair portrayal.” As I posted before, I let the ASB do their own talking on that point.
“The most fundamental proposed change is [t]o a set of minimum Standards Rules that an appraiser [FONT=TimesNewRoman,Bold]must [/FONT]adhere to in every assignment.”.
“This would move USPAP from a set of standards with [e]xceptions to [a] set of minimum standards from which exceptions are not permitted.”
I accept their portrayals of the intent and the finished product.

Getting back to the case study. It’s not that I don’t understand this abstract minimalist theory, it’s that I think it’s pointless and society will never buy into it. The case study should advise using SWAG Value or Ballpark Value for at least the first appraisal. What happens when one of the parties involved in the case study decides to sue you, claiming harm because they relied on the wrong spin of the scope-of-work roulette wheel? Do you expect a judge or jury to buy into your theory that the client has the “responsibility?”

I'll be the first person to admit that I've learned a lot about appraisal standards in the last few years and while we're at it, to credit some of that understanding to what I've learned from you. Hopefully I do have a better understanding of it now than I did in 1999 and hopefully I'll be farther along in 2010 than I am now.
If I could really teach anyone anything, I‘d teach objectivity and independence. Is it going to be sometime after 2010 when you can finally find a flaw in something one of the ASB writes instead of trying to spin into something more reasonable than it is? :icon_smile: The ASB has a lot less trouble then you criticizing USPAP. Foreword 06 says the 12-year old formal jargon of “complete appraisal” and “limited appraisal” is “misleading.” And that while the 05 USPAP says using the term “limited” is something that makes the appraisal “clear.” Now that is ham-handed.


It’s not my goal in life to be the Simon Cowell of exposure drafts, but that doesn’t mean there isn’t a serious question why anyone might need a set of appraisal standards that don’t explicitly require anything more than no-inspection ballpark estimate of SWAG value. You think these characterizations are “unfair,” but that doesn’t mean they are not 100% accurate. .
- Anything that could be cited as a trigger mechanism to requiring more scope than a no-inspection ballpark estimate comes from external sources (e.g., supplemental standards, client demands, opinions about typical practice and sophisticated-user expectation). How can you find it praiseworthy that a national standards board simply gets out of the way and allows everyone and everything else dictate appraisal standards?
- USPAP requirements are too minimal by themselves to be “generally accepted practice.” No major client group will accept work that is not subject to additional standards. The irony is that Congress picked the ASB to make standards for FRT’s and USPAP doesn’t even cover those. The federal regulatory agencies have supplemental standards, too. :icon_smile:
 
" Anything that could be cited as a trigger mechanism to requiring more scope than a no-inspection ballpark estimate comes from external sources (e.g., supplemental standards, client demands, opinions about typical practice and sophisticated-user expectation). How can you find it praiseworthy that a national standards board simply gets out of the way and allows everyone and everything else dictate appraisal standards?
- USPAP requirements are too minimal by themselves to be “generally accepted practice.” No major client group will accept work that is not subject to additional standards. The irony is that Congress picked the ASB to make standards for FRT’s and USPAP doesn’t even cover those. The federal regulatory agencies have supplemental standards, too. "

I think most of "the market" is winning and has been winning since the first diminimis increase, if winning is reversing the potential grip of Title 11. However, appraisers got stuck with multiple flavors of state board interpretations out of the deal and lots of USPAP CE. And the appraisal organizations and designated members got demoted drip by drip and license by license.

The Communist Manifesto took a long time to write. I think they are still getting the kinks out of it. Darn, it's hard to anticipate everything. I like the new rules, but it doesn't expose the FIRREA licensing scandal that leads the unsuspecting general public to trust standards that are enforced by the secondary market like Steve points out, with licensing getting unearned credit.

The question is...(perhaps, the irony is) does the system itself promote the public trust? If so, is it because it successfully has duped the public?
 
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