Bill Pastuszek, Shepherd Associates

There is much that is right with the changes made to USPAP over a decade. The changes to Scope of Work are still among the most important ever made and make the central concept easy to understand by both appraisers and appraisal users. Over time, many formatting and organizational changes have been made for ease of reference of understanding. The document is reasonably easy to navigate, with a well done index, and searchable electronic editions are available. USPAP is also much more fun to teach than it used to be, (Fun you say? USPAP? Yes, USPAP! Come to a face to face class some time: you’ll see!)

The 2016 edition saw the demise of statements, with the material either subsumed into USPAP itself or transported into advisory opinions. While no one ever had any particular love for the statements (whether or not they were methodology or not being largely a moot point) I don’t think anyone has much of an issue with the form of the changes. However, an additional element of complexity is added as to where the guidance now is buried.

If advisory opinions (AOs) are so important, why aren’t they part of USPAP? The distinction is lost among many users. Why are they “other communications?” In the real world the distinction drawn is at the least, unclear, and, at worst, dangerous. In the interests of much-beloved clarity, the standards board should recognize that most of the appraisal-related public believes AOs to be part of USPAP.

More recently, USPAP seems to undergo endless refinements and “edits for clarity” sake.

Remember the last USPAP cycle? Reporting options changed. Many client groups (and appraisers) are still digesting those changes. Three confusing report labels were made into two insufficiently useful options. End result: many clients and appraisers have come up with their own labels, and appraisers are left with vague guidance such as “the level of detail should be consistent with the requirements of the intended use.” Weren’t reporting options supposed to provide guidance to appraisers, users, and the enforcement community about how much or little detail is sufficient to meet the “intended use” threshold. The current system leaves a high level of interpretation up to the “market,” exactly what USPAP is supposed to help avoid.

Past appraisal standard boards have tried, but not succeeded, in changing the reporting standard to meet some of the “communications” issues regarding reporting without success. Guidance is needed so that the comes to consensus in terms of the communications part of appraisal, just as it was able to find common ground around scope of work.

It seems especially futile that the drafts issue is left unresolved (unaddressed may be better said). It’s difficult to know how various configurations of standards boards haven’t been able to find ways to resolve the issue, either directly or obliquely. USPAP still does not address drafts, or record retention regarding “interim communications.” What limited guidance there is found in FAQs. The industry experiences confusion about drafts, report revisions, transmission of assignment results, and record retention. There is no doubt that there is lack of industry agreement on this issue; that is why appraisers need to have specific directives. This is a core issue that falls within the grasp of USPAP and the mission of the Standards Board.

The last two USPAPs have provided revisions to “assignment results.” This central USPAP concept, still is not entirely clarified c. 2016. It would not be surprising to see yet another revision made in the interests of “clarity” in 2018.

Recent USPAP editions have changed, “tweaked” as it were, definitions, comments, and other “fine print” parts. The rationale for many of these changes is to increase clarity and understanding, suggesting that prior boards did not get it right. A vocal minority believes there is too much tinkering with a document already too complex without having to digest major overhauls every cycle. Many appraisers just want to be able to do their jobs

Does USPAP change too much? Yes and no. These are trying times for appraisers. In 2014, Standard 2 (along with large affected portions of USPAP) changed. In 2016, USPAP experienced substantial overhauling due to eliminating statements. In prior years, a number of rules were overhauled. Were these changes necessary? Probably. Is the document more understandable and clear? Hope so. Do FAQs help in understanding USPAP? Absolutely. Is there the feeling out there that too much USPPA tinkering going on? Yes.

The USPAP public wants consistency and understandability. Many believe that recent USPAP changes represent a trend toward churning, wordsmithing, and change for the sake of change (or until it’s finally right) rather than signifying fundamental improvements to the document. USPAP is too important to too many careers to undergo what appears to some to be restless change for change’s sake. There are bigger issues that USPAP needs to address to meet the pressure for change that the profession is experiencing.

Bill Pastuszek, MAI, ASA, MRA, heads Shepherd Associates, Newton, Mass.