The National Association of Appraisers (NAA), in a letter to The Appraisal Foundation’s (TAF) Appraisal Standards Board (ASB), expressed support and recommendations regarding the First Exposure Draft of Proposed Changes for the 2020-21 Edition of the Uniform Standards of Professional Appraisal Practice (USPAP).
In a letter dated July 12, NAA President John Dingeman outlined his organization’s support and selected recommendations as it pertains to the draft.
Dingeman made observations concerning Section 1 (Reporting Options), Section 2 (Scope of Work) and Section 3 (Comments in Standard Rules).
“The NAA is in support of the proposed changes to STANDARD 2: REAL PROPERTY APPRAISAL, REPORTING,” Dingeman wrote. “NAA is supportive of these changes; particularly removal of DISCLOSURE OBLIGATIONS from this section. NAA is in agreement with the rationale for moving into the Standards Rule itself most of the Comments that contain requirements. We encourage, however, that the language in the comment on lines 385‐388 (or language similar to it) be moved to the USPAP Preamble: Perfection is impossible to attain, and competence does not require perfection. However, an appraiser must not render appraisal services in a careless or negligent manner. This Standards Rule requires an appraiser to use due diligence and due care.”
Section 4 of the Exposure Draft, dealing with Definitions, was another area the NAA commented on.
“NAA generally supports changes and additions to Definitions; however, we respectfully request that the clarifying language ‘Physical characteristics are not assignment results’ on line 609 remain somewhere within USPAP if not within the definition of Assignment Results,” Dingeman wrote. “We also wish to request clarification for the need of the parenthetical phrase ‘(DATE OF VALUE)’ on line 633 as this appears to have the potential to create confusion.
“While we are supportive the addition of a definition of INSPECTION beginning on line 658, we request careful thought and consideration to the final language in this definition to avoid confusion among practitioners, users of appraisal services and regulators regarding real property inspection requirements and allowable reliance upon data provided by third-party inspectors,” Dingeman continued.
In Section 5: Other edits to improve clarity and enforceability of USPAP, NAA expressed support of the rationale and changes proposed, while extending its appreciation for the opportunity to provide feedback on this exposure draft.