Per the AF and ASB "All interested parties are encouraged to comment in writing to the ASB before the deadline of February 1, 2019. Respondents should be assured that each member of the ASB will thoroughly read and consider all comments.
Comments are also invited during the ASB Public Meeting on February 8, 2019 in Scottsdale, AZ.Written comments on this exposure draft can be submitted by mail and email.Mail:
Appraisal Standards Board
The Appraisal Foundation
1155 15th Street, NW, Suite 1111
Washington, DC 20005
Email: asbcomments@appraisalfoundation.org"
For the full exposure draft, follow the source link below.
The ASB executive summary
Source: The Appraisal FoundationThis Executive Summary is intended to be a brief discussion of each section in the document. Because some readers may not have an interest in every section of the document, the Executive Summary gives an overview to help readers find the sections related to their specific interest(s).
For detailed information on proposed revisions and the reasons for the proposals, the ASB encourages readers to review the rationale as well as the specific changes being proposed. As always, the ASB requests readers to submit any relevant comments.
Section 1 – STANDARDS (Reporting Options and Comments in Standards Rules)
Reporting Options
The ASB proposes significant revisions to STANDARDS 2, 8, and 10. Rather than limiting appraisal reports to either a one-size-fits-all or the current two-sizes-fit -all reporting options, the ASB proposes a model that reduces the specificity without diminishing the USPAP reporting requirements. The Board also proposes the elimination of required appraisal report labels and specific warning language but proposes reporting rules that require clear and conspicuous disclosure of any restrictions on the use of an appraisal report. The ASB also proposes some parallel changes to STANDARDS 4 and 6 as appropriate for consistency.
Comments in Standards Rules
In the First and Second Exposure Drafts the ASB proposed several actions related to Comments in the Standards Rules. These actions included deleting some Comments that had duplicate requirements clearly stated elsewhere and incorporating others directly into the Standards Rules. The responses to the First and Second Exposure Drafts indicated these actions were helpful in increasing the clarity of USPAP. In response to stakeholder input, this Third Exposure Draft includes a proposal to revise the structure of the long Comment following the Certifications and to reinstate some of the Comments that had been proposed for deletion.
Section 2 – SCOPE OF WORK RULE
After considering responses to the First and Second Exposure Drafts regarding proposed modifications to the Disclosure Obligations section of the SCOPE OF WORK RULE, the ASB now proposes to add language to the Disclosure Obligations section of the SCOPE OF WORK RULE to address the flexibility afforded the appraiser in the disclosure of scope of work.
Section 3 – COMPETENCY RULE
In earlier exposure drafts, the ASB proposed to move the following important Comment from Standards Rules 1-1, 3-1, 5-1, 7-1, and 9-1, and add a slightly edited version to the COMPETENCY RULE. In response to comments to the Second Exposure Draft, the ASB now proposes to move the unedited Comment, as follows, into the COMPETENCY RULE.
“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 Rule requires an appraiser to use due diligence and due care.”
This particular Comment currently appears only in the development Standards, but it has been pointed out that it should also apply to reporting. Moving it into the COMPETENCY RULE reduces duplication and, at the same time, broadens the applicability of this important Comment since the COMPETENCY RULE applies to both development and reporting in all disciplines.
Section 4 – DEFINITIONS
Based upon responses received from the First and Second Exposure Drafts, the ASB proposes some modifications and additions to the DEFINITIONS in order to help readers better understand USPAP. Both exposure drafts proposed to include USPAP terms that differ from or are not found in popular English dictionaries and also, in a few instances, to indicate which popular dictionary definition is meant to be used if there are multiple definitions.
Section 5 – Other Edits to Improve Clarity and Enforceability of USPAP
The Board proposes several edits for clarity and consistency. The edits are related to the following three terms or phrases:
1.Accept an assignment
2.At the time of the assignment
3.Intangible Items
In response to comments received from the Second Exposure Draft, the proposed DEFINITION of “At the time of the assignment has been modified.”
Section 6 – Proposed Revisions to ADVISORY OPINION 1, Sales History
The Board is proposing edits to provide additional detail related to an appraiser’s obligation to analyze the sales history of the subject property. In addition, the Board is proposing corresponding edits that will be made if the changes to USPAP contained in this Third Exposure Draft are adopted.
Section 7 – Proposed Revisions to ADVISORY OPINION 2, Inspection of Subject Property
The Board is proposing edits to reflect changes in the marketplace related to an appraiser’s inspection of a property. In addition, the Board is proposing edits that will be made if the definition of INSPECTION contained in this Third Exposure Draft is adopted.
Section 8 – Proposed Revisions to ADVISORY OPINION 3, Update of a Prior Appraisal
The Board is proposing edits that clarify an appraiser’s obligations regarding confidentiality when performing an update of an appraisal using the “incorporate by reference” option.
Section 9 – Proposed Revisions to ADVISORY OPINION 28, Scope of Work Decision, Performance, and Disclosure
The Board is proposing clarifying edits to Illustration 2, and to include an additional illustration regarding a scope of work problem related to real property. In addition, the Board is proposing corresponding edits that will be made if the changes to USPAP contained in this Third Exposure Draft are adopted.
Section 10 – Proposed Revisions to ADVISORY OPINION 31, Assignments Involving More than One Appraiser
The Board is proposing edits that will be made if the definition of SIGNIFICANT APPRAISALASSISTANCE contained in this Third Exposure Draft is adopted. Additional edits are being proposed if the edits to Standards Rules 2-3, 4-3, 6-3, 8-3, and 10-3 in the Third Exposure Draft are adopted.
Section 11 – Proposed Revisions to ADVISORY OPINION 32, Ad Valorem Property Tax Appraisal and Mass Appraisal Assignments
The Board is proposing to add an Illustration 5, capturing information proposed for deletion from a Comment to Standards Rule 5-5(a), which the Board concluded was more advisory in nature and better placed in this Advisory Opinion. Additional edits are being proposed based on the potential changes to USPAP in this Third Exposure Draft.
Section 12 –ADVISORY OPINION 38, Content of an Appraisal Report
The Board is proposing a new Advisory Opinion that will replace Advisory Opinions 11 and 12 if the proposed edits to USPAP in this Third Exposure Draft are adopted.
Section 13 – Proposed Retirement of ADVISORY OPINION 4, Standards Rule 1-5(b); ADVISORY OPINION 11, Content of the Appraisal Report Options of Standards Rules 2-2, 8-2, and 10-2; and ADVISORY OPINION 12, Use of the Appraisal Report Options of Standards Rules 2-2, 8-2, and 10-2
The Board is proposing the retirement of AO-4 as the existing guidance is viewed as narrowly-focused, and is more appropriately housed where it also currently exists in the USPAP Frequently Asked Questions.
As stated above, AO-11 and AO-12 will be retired and replaced with AO-38 if the proposed revisions to USPAP contained in this Third Exposure Draft are adopted.
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