The ASB reports
Source: Appraisal Foundation2018-14: USPAP COMPOSITION, STRUCTURE, AND COMPLIANCE At The Time Of The Assignment
Question: The phrase “at the time of the assignment” is used in a number of places in USPAP. Does this only mean at the very beginning of the engagement process or can it refer to other times during the development of the assignment results?
Response: “At the time of the assignment” refers to the time period commencing with the appraiser’s agreement to perform a valuation service and ending with the completion of the assignment.
2018-15: RECORD KEEPING RULE Government Agency Workfile Retention
Question: I am a review appraiser employed by a federal government agency. The agency’s record retention policies for appraisal and appraisal review reports meet or exceed the requirements of the RECORD KEEPING RULE in USPAP. My workfile is considered a government record, which I have access to throughout the USPAP retention period. Am I required to keep a separate workfile in my personal custody?
Response: No. The RECORD KEEPING RULE states that an “appraiser must have custody of the workfile, or make appropriate workfile retention, access, and retrieval arrangements with the party having custody of the workfile.” Since your employer’s record retention policies meet or exceed the requirements of USPAP and you have access to the workfile during that retention period, you are not required to maintain a separate copy of your workfile.
2018-16: APPRAISAL REPORTING – CERTIFICATION AND SIGNATURES Prior Service and Professional Assistance Disclosures – Part 1
Question: I work for “Large National Appraisal Firm,” which has multiple offices. In situations where appraisers on staff have valued properties within the prior three years, the firm’s management recommends its appraisers utilize the following language in the certification to disclose prior services: “Large National Appraisal Firm has provided a prior service, as appraisers, but has provided no other services, as appraisers or in any other capacity.” Is this a proper disclosure under USPAP?
Response: No. Firms do not sign certifications. Appraisers sign certifications. The disclosure in the certification must clarify whether the individual appraiser who signs the certification has provided prior services. The same requirements apply if the certification is signed by appraisers who have different records of prior services. The certification must indicate which appraisers provided prior services (and what services) and which appraisers have not provided any services, as an appraiser or in any other capacity, during the three-year period immediately preceding engagement to complete the assignment.
2018-17: APPRAISAL REPORTING – CERTIFICATION AND SIGNATURES Prior Service and Professional Assistance Disclosures – Part 2
Question: I work for the multi-office “Large National Appraisal Firm.” The firm’s management recommends staff appraisers include the following generic disclosure language in the certification to identify instances where staff members have provided significant real property appraisal assistance: “Staff members of Large National Appraisal Firm have provided significant professional appraisal assistance to the persons signing this certification.” Is this a proper disclosure under USPAP?
Response: No, this is not a proper disclosure. The names of individuals providing significant appraisal assistance must be stated in the certification. It is not required that the description of their assistance be contained in the certification, but the extent of their assistance must be stated or summarized within the appraisal report in accordance with Standards Rule 2-2(a)(vii) or 2-2(b)(vii) as applicable.
USPAP Q&A Page 3 2018-19 USPAP Q&A June 27, 20182018-18: RECORD KEEPING RULE Testimony and Deposition
Question: I completed an appraisal report that was used by my client in litigation. My report was entered into evidence, but I did not provide a deposition and did not testify at the trial. How long must I retain my workfile since there was a judicial proceeding?
Response: The RECORD KEEPING RULE states: “An appraiser must retain the workfile for a period of at least five years after preparation or at least two years after final disposition of any judicial proceeding in which the appraiser provided testimony related to the assignment, whichever period expires last.” (Bold added for emphasis) In this scenario, the appraiser did not provide testimony, therefore the workfile must be retained for a minimum of five years after preparation.
2018-19: RECORD KEEPING RULE Retention Requirements for Preliminary Communications after Completion of the Assignment
Question: During the course of the assignment, my client has asked me to provide the sale comparables I plan to use, as well as information on my rent and expense conclusions, prior to the completion of my Appraisal Report. If I subsequently provide an Appraisal Report, does my workfile need to contain a written copy or summary of the communication previously transmitted to the client?
Response: No. Upon completion of the assignment, the assignment results are communicated to the client within the Appraisal Report. The RECORD KEEPING RULE requires the workfile to contain a true copy of the report as well as all data, other information and documentation necessary to support the appraiser’s opinions and conclusions. State requirements may add to USPAP obligations therefore appraisers should check with their state to see if additional requirements apply.
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