The exposure draft has contact information for making comments on the proposed changes, but keep in mind this is only the first draft of changes for the 2012-2013 edition of USPAP.
The exposure draft, dated January 5, 2010 states
The most important issue that has arisen over the past several years is the need for clearer expectations of an appraiser’s responsibilities when communicating in all parts of appraisal practice.
For the 2012-2013 edition of USPAP it is the ASB’s intent to clarify, in the Standards, what should or should not be required in a report. But prior to this there is a clear need to address the diverse communications that appraisers commonly provide their clients, prospective clients and users of appraisal services, that fall outside final assignment results. This has been referred to as “fundamentals” of communication. The ASB agrees that this clarification of fundamental communication responsibilities within appraisal practice must be addressed before any additional conceptual or structural changes to the reporting requirements in the Standards can be considered.
Therefore, just as the SCOPE OF WORK RULE was created to provide clarity in how to determine and disclose the array of services that appraisers provide for their clients, the ASB believes it will be valuable to have a similar Rule that provides clarity in how to address and disclose the diverse levels of communication that clients request or require.
The COMMUNICATION RULE is proposed for placement following the SCOPE OF WORK RULE. It begins with recognition of the primary expectation of the PREAMBLE that “it is essential that appraisers…communicate…to intended users of their services in a manner that is meaningful and not misleading.” It also clearly places responsibilities on appraisers to serve the public trust during communications at all stages of any service provided as part of appraisal practice.
The Rule covers appraisers’ responsibilities through all their activities, including everything from initial contact with potential clients to interactions with a client, intended users or other relevant parties following completion of an assignment. The Rule does not, however, include or address business-related communication such as completion dates, the timeframe for inspection of the property, or similar activities that are best classified separately as general business practices. Nor is this Rule intended to regulate internal communications among appraisers and others who are working together in an assignment.
In order to establish the best possible format for receipt of constructive comments, the ASB chose to draft and expose for comment two alternatives of a proposed COMMUNICATION RULE.
Both alternatives have similarities:
- The definition of Report has been revised.
- The Rule adds clarification to when an appraisal assignment is complete.
The two alternatives differ in their position on how to address draft or preliminary communication of all, or part, of an appraiser’s analyses, opinions and conclusions in an assignment.
- The Rule identifies minimum information that must be included in the communication of results for assignments other than those already specified in USPAP for appraisal, appraisal review and appraisal consulting assignments.
To read the full (15 pages) exposure draft, click HERE.The essential difference between Alternatives A and B of the COMMUNICATION RULE are these:
- The allowance of only those reports that comply with reporting Standards, versus the inclusion of additional, allowable forms of communication and additional definitions.
- How communication of all or part of an appraiser’s analyses, opinions and conclusions of assignment results must be reported under USPAP.
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