USPAP - Fourth Exposure Draft for 2012-2013

The Appraisal Standards Board (ASB) has issued the fourth exposure draft for the 2012-2013 edition of USPAP.  The comment period on this draft runs until January 14, 2011. The first several 2012/2013 exposure drafts were focused on report writing, while the third draft dealt with the communication rule. The fourth exposure draft is intended to improve clarity, relevance and enforceability.

If necessary a 5th exposure draft will be published in early February with a final version  expected to be adopted in April.

The ASB exposure draft states

The ASB’s original goals for the 2012-13 edition of USPAP were to review and revise as needed the following areas of USPAP:

Reporting Requirements

Reporting Options


Other revisions and additions as needed to ensure clarity and relevance.

The First and Second Exposure Drafts included a major emphasis on reporting. This included reconsideration of the appropriate, minimum expectations that should exist whenever appraisers communicate opinions or assignment results to their clients and other intended users.

The ASB believes the minimum reporting requirements of the various Standards could be more useable and understandable. A predominant opinion is that limiting the number of specific reporting formats and allowing more flexibility in communicating the depth of content in any particular area would be beneficial for appraisers, clients, intended users, and reviewers. This proposal was exposed in the Second Exposure Draft.

Previous modifications of USPAP’s development requirements included removal of more rigid, specific departure provisions with a singular SCOPE OF WORK RULE that gave appraisers more flexibility and address only relevant issues. The SCOPE OF WORK RULE outlined an appraiser’s responsibilities when determining what must be considered when developing an opinion. The ASB believes that allowing more flexibility in what must be communicated or reported to a client or intended users should also be more flexible. But it must also include related general rules that outline the minimum requirements of an appraiser whenever they are communicating assignment results and conclusions to a client or intended user. This was exposed as a COMMUNICATION RULE in the First and Second Exposure Drafts.

The ASB’s Third Exposure Draft, dated September 29, 2010, included notification that the proposed addition of the COMMUNICATION RULE intended to identify minimum expectations of appraisers in all relevant communications with clients and intended users was being removed from the goals for the 2012-13 edition of USPAP. Revisions proposed for reporting formats were also removed. The ASB’s challenge was simple: there was strong support for the proposal to reduce the reporting format options to the proposed two, or even to one. However, there was also a significant outcry against any articulation of expectations on the part of appraisers on any communication provided to a client or intended user prior to completion of a report.

Public comments following this announcement in the Third Exposure Draft expressed disappointment that, at a minimum, the modifications to the reporting formats were not retained. However, the ASB continues to believe that these two issues: allowing for more flexibility in how an opinion is communicated; and clarifying the minimum responsibilities an appraiser has when communicating opinions, cannot be addressed separately. Thus, the two issues will continue to be withheld from the proposed revisions to the 2012-13 edition of USPAP and studied for possible inclusion in the 2014-15 edition of USPAP.

This Fourth Exposure Draft continues its refinement of additional changes to USPAP that are intended to improve its clarity, relevance and enforceability. These proposed revisions and the subsequent public comment will be considered at the January 21, 2011, meeting of the ASB in Scottsdale, Arizona.

Click HERE to read the full PDF version of the ASB USPAP exposure draft.

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