USPAP True Copy

[incognito]

As of 9/1/2011, if you do residential work for GSA's which will be subject to the new UAD requirements, there are somethings you must know. When a UAD 1004 (or other UAD report) is completed, you will end up with a report with UAD compliant entries. Up until now, this copy, be it a hard copy or a computer file, would be our USPAP "True Copy".

However, if you are sending the report to a client who requires UAD reports to be sent to the Uniform Collateral Data Portal (most non-VA or non-FHA will require this), it will be sent to this proprietary portal, and I believe it will have to be sent using AI Ready conversion or Lighthouse conversion. The PDF will be "wrapped" with XML or MISMO data, and will be sent to the portal, and the "wrapped" data will be stripped and mined by FNMA!

So, in effect, the USPAP "True Copy" of the report will have to be the "wrapped PDF", and a file paper copy can no longer serve as a true copy, for USPAP purposes...

Correct me if I am wrong, but this is what I gather at this point...

 

[George Hatch]

This is a variation of the debate we had over the AI Ready format a few years back.


The term "true copy" is not among the defined terms in USPAP, but "Report" is.

"REPORT: Any communication, written or oral, of an appraisal, appraisal review, or appraisal consulting service that is transmitted to the client upon completion of an assignment."

The above definition doesn't say anything about any limitations on the number or types of reports that can be issued per assignment. I don't see any reason why an appraiser couldn't issue an oral report, hardcopy report, pdf report or a report in any other electronic file format for the same assignment. Likewise I don't see anything in USPAP that indicates that any of those versions is more or less valid than the others. The appraiser's responsibility in an assignment isn't limited to one report, but to all reports they prepare.

The Record Keeping section of the ETHICS RULE requires appraisers to retain a copy of all reports they send out. If you generate an XML version of your appraisal report and transmit it to your client I suppose you would have to keep a copy of that file as well as retaining access to the software that runs it.

OTOH, if a third party generates a "version" of your appraisal report and sends that off I don't see anything in the Record Keeping section that would require you to keep that. If you didn't generate it then it isn't your report; it's just a copy, facsimile or version of your report. If someone has a problem with a copy of your report prepared by someone else I think your liability would be limited to whatever it is you actually did - they'd come back to whatever you prepared and sent to your client.

 

[DWiley]

This is disccused in the AI UAD seminar.

USPAP defines a report in terms of the thing transmitted by the appraiser. Under UAD, the thing that will be transmitted is an XML file that contains an imbedded PDF file. Since that XML file is the thing generated and transmitted to the client, then the XML file is the true copy.

A similar thing applies today to AIReady files. The env file is the true copy, because that is what the appraiser transmits.

 

[RSW]

This is disccused in the AI UAD seminar.

USPAP defines a report in terms of the thing transmitted by the appraiser. Under UAD, the thing that will be transmitted is an XML file that contains an imbedded PDF file. Since that XML file is the thing generated and transmitted to the client, then the XML file is the true copy.

A similar thing applies today to AIReady files. The env file is the true copy, because that is what the appraiser transmits.

I agree. I keep my original appraisal file - a-la-mode in PDF, the AI Ready PDF file, and the env file in my workfile.

 

[Mike Kennedy]

I agree. I keep my original appraisal file - a-la-mode in PDF, the AI Ready PDF file, and the env file in my workfile.

.......Ditto........I also print hard copy of the ENV (never trust computers).

 

[Peter LeQuire]

.......Ditto........I also print hard copy of the ENV (never trust computers).

True dat...

 

[RSW]

.......Ditto........I also print hard copy of the ENV (never trust computers).

How are you printing a hard copy of the env file? I just print a copy of the AI Ready file.

 

[Couch Potato]

A true copy is a duplicate without alterations. I have always stored in my files a copy in the same format I delivered. I don't think a paper copy has ever met the definition of a true copy of a report delivered as an electronic file. Non-visible content exists in all PDF reports. Both prior to UAD and after UAD I doubt appraisal boards will push the issue. It is only in court that it is likely to be an issue for those changing formats.

 

[Mr Rex]

A true copy is a duplicate without alterations. I have always stored in my files a copy in the same format I delivered. I don't think a paper copy has ever met the definition of a true copy of a report delivered as an electronic file. Non-visible content exists in all PDF reports. Both prior to UAD and after UAD I doubt appraisal boards will push the issue. It is only in court that it is likely to be an issue for those changing formats.

So are you saving a PDF "copy" of the env from the OADI reader? or are did you break down and pay $500 or so for the Adobe Pro X, CSS, or whatever that can open the env on its own? Is the pdf "copy" really a true copy of an "open" transmission?

 

[Riick]

How are you printing a hard copy of the env file? I just print a copy of the AI Ready file.

Same question!