USPAP - Workfile Requirements

[JohnCreaser]

Is there a section in USPAP that states what is and is not required to be included in the workfile? I put all data (RealQuest, MLS, County Records, actual inspection sheet, sketch) acquired for comps/listings that I use in the report, but was made aware that I need to include comps & listing that I didn't use to show what I picked from. Is there such a requirement or USPAP clarification that states this as I have a meeting Monday morning with an investigator about this missing in my workfile? Investigator also stated I need to show in my workfile the search parameters used....most of our searches are done via internet and we only select the credible properties that we deem salient for our search. Never knew I had to do a screen shot and save it in the workfile. Any help on this is extremely helpful as I try to defend my workfile.

 

[Tom Woolford]

When I do my searches, my MLS gives an option to display the search parameters. I print the result page to PDF and include in the workfile. That of course goes for any refined searches also. I do the same if searching assessor records. In general, if I looked at it, it goes in the workfile. Since its all digital, its no big deal. That goes for emails, and status pages from an AMC if applicable.

 

[JohnCreaser]

If you do your original search and pull up 75 sales, do you put all 75 sales in the workfile? Investigator is saying you have to regardless if you narrowed your search down to 6 or 8 sales. I've been searching the internet looking for any requirement that states you have to show every sale or just the sales you used within the workfile. The only thing I can find is below and nowhere does it state what the Investigator mentioned he is looking for.

The workfile must include:
the name of the client and the identity, by name or type, of any other intended users;
true copies of any written reports, documented on any type of media (A true copy is a replica of the report transmitted to the client. A photocopy or an electronic copy of the entire signed report transmitted to the client satisfies the requirement of a true copy.);
summaries of any oral reports or testimony, or a transcript of testimony, including the appraiser’s signed and dated certification; and all other data, information, and documentation necessary to support the appraiser’s opinions and conclusions and to show compliance with USPAP, or references to the location(s) of such other documentation.

 

[CANative]

I'm starting to worry that as state enforcement agencies come under pressure by lenders/borrowers etc. they're going to start making up requirements as they go along.

 

[MN Mark]

.......
The workfile must include:

........

..... and all other data, information, and documentation necessary to support the appraiser’s opinions and conclusions......

Seems to me, that would have to be the basis they're using to say the comps considered but not used are required. Personally, I'd think that the comps that you didn't use only tell you what the subject's value isn't, and not what it is, but then, really, that is part of the process. So I think it could be argued either way. I guess what they are looking for is did you use sound reasoning in your selection of comparables. I think the downside to having only the comps you used in the file is it leaves you open for an accusation that you pre-selected your comps. And that leaves you open to an accusation that you were working towards a target.

I once had a seller file a complaint against me because I didn't "make value". When I received the nastygram from the state asking for my rebuttal, among other things, they required that I submit MLS printouts for the comparables that I used and MLS printouts for the comparables that I considered but didn't use, along with a brief explanation for each as to why I didn't use them. So I would say the request from your state is not unusual, even if it is a liberal interpretation of USPAP. In my case, the file was closed with no action taken, but not before they ran me through the wringer and tried to make me sweat. At the time I swore the accusatory tone and 'guilty until proven innocent' approach was just their attempt to put the "fear of God" into me.

My guess as to why they want the search criteria is that they are looking for some kind of proof that part of your search criteria wasn't something like: $220,000 to $240,000. By keeping a variety of comparables that you didn't use in the file, I would think it would help make the case that you didn't search by price range, even if you didn't keep a printout of the criteria used. And maybe that's the point in asking for the comps you didn't use, as in, looking to determine if you were willing to consider that the subject's value might be something other than what you ended up with by having a variety of prices in your potential comps.

 

[panappr]

I'm starting to worry that as state enforcement agencies come under pressure by lenders/borrowers etc. they're going to start making up requirements as they go along.

That's what I was thinking.... Problem is there has to be a
line for common practices.

 

[CANative]

It's still up to the individual investigator and how they see things.

 

[Metamorphic]

I've been wondering about this too. I've got good records on what I use. But I typically do a half dozen or more searches to find comps; gradually narrowing the specifications to identify the most similar, then widening them out based on specific parameters to identify properties that will provide an indication of value of any peculiar amenities or location oddities that the subject has. To really turn all that into a meaningful, auditable record I'd have to add a lot of meta data to the pdfs to tell you what each search was and why it was run and then for each of the properties that turned up on the search to say why it was discarded. That would easily double the comp search time.

 

[DTB]

If they say zzz is required, have them demonstrate the rule, requirement, regulation... that states that. Specifically.

 

[LI-Appr]

No problem Met just bill them for it. I am sure the lender is willing to pay for a quality report. OOps, the lender is one of the bailedout banks. Sorry.