Which USPAP?

[Financially Feasible]

Obviously, the new USPAP goes into effect tomorrow. I have done some research into this question but have not been able to find a definitive answer.

The question is: effective date of valuation is December 2013 and the date of the report will be in January 2014. Therefore... which USPAP will govern the report? Is the effective date used or the date of the report?

USPAP FAQ #146 addresses a similar question for retrospective appraisals:

146. USPAP COMPLIANCE IN RETROSPECTIVE APPRAISALS

Question: When preparing an assignment with a retrospective date of value, should the appraiser comply with the USPAP in effect as of the date of the appraisal or as of the date of report?

Response: Appraisers must comply with the USPAP edition in effect as of the date of the report. Only the data and the analyses of that date should be considered on a retrospective basis, not the Standards under which the assignment is performed.

Therefore, would the date of the report determine the applicable USPAP to follow (and, in the example cites, that means that the 2014 USPAP should be followed)?

Can anyone point me to the language where USPAP discusses this issue? I'm sure that it is looking me right in the face... :Eyecrazy:

And yes... I am aware that FAQs are considered "other communications" issued by the ASB and are not a part of USPAP.

 

[PDXOregon]

People have been saying date of report that means effective date. The effective date is the USPAP you use.

 

[CANative]

YOU, as the reviewer, comply with the USPAP as of the date of your assignment. Part of your assignment might be to confirm that the report under review complies with USPAP as of the effective date of the work.

I suppose I can find this somewhere unless someone else does it first.

 

[Financially Feasible]

YOU, as the reviewer, comply with the USPAP as of the date of your assignment. Part of your assignment might be to confirm that the report under review complies with USPAP as of the effective date of the work.

I suppose I can find this somewhere unless someone else does it first.

Sorry if I was unclear. The question deals with neither a retrospective appraisal nor an appraisal review. The issue is for a current valuation where the effective date is in December of 2013 and the date of the report (the date where the report is finalized and signed) is in January of 2014. Which USPAP would govern the report?

 

[CANative]

I'd go with the date of report controlling the USPAP version used.

 

[stefan olafson]

You are bound by USPAP to reference or utilize the USPAP that is in effect at the time you are completing the appraisal. So in your instance you would follow the new and better 2014 USPAP.

 

[Don Clark]

The date you report the appraisal would be the date for compliance with USPAP that is effect as of that date. You are doing many task prior to a report. But, it is a matter of choice as to the effective date. I would simply make the effective date a date after 1-1-2014 and you have solved the problem. You do not, contrary to popular belief, have to make the effective date the date of the inspection.

 

[BRCJR]

The date you report the appraisal would be the date for compliance with USPAP that is effect as of that date. You are doing many task prior to a report. But, it is a matter of choice as to the effective date. I would simply make the effective date a date after 1-1-2014 and you have solved the problem. You do not, contrary to popular belief, have to make the effective date the date of the inspection.

Don,

If you make the effective date 1/1/14 and deliver the report to the client that day, you inspected the property 12/30/13 and it was damaged on 12/31/13 unbeknownst to the Appraiser:

How can you make the effective date after your inspection without being misleading?

Maybe I am not understanding what you are saying can be done in this type of instance.

 

[CANative]

The date you report the appraisal would be the date for compliance with USPAP that is effect as of that date. You are doing many task prior to a report. But, it is a matter of choice as to the effective date. I would simply make the effective date a date after 1-1-2014 and you have solved the problem. You do not, contrary to popular belief, have to make the effective date the date of the inspection.

If it's a GSE, FHA or VA appraisal the date of inspection is the effective date of value.

And it only makes sense to use the more current USPAP (date of report) since reporting standards must meet the requirements of the current USPAP.

 

[Mike Kennedy]

USPAP 2014-15

"SR 2-2(a)(iv)
(vi) state the effective date of the appraisal and the date of the report;

713 Comment: The effective date of the appraisal establishes the context for the value opinion, while the date of the report indicates whether the perspective of the appraiser on the market and property as of the effective date of the appraisal was prospective, current, or retrospective."