T.J. McCarthy, of T.J. McCarthy & Associates, Tinley Park, IL has the following assessment of the ASB's most recent Q&A. The following is being reprinted from an Illinois Coalition of Appraisal Professionals (ICAP) alert.
The Appraisal Standards Board (ASB) has just issued their July 2008 USPAP Q&A - Download July_2008_QA.pdf with the following questions/topics:
This is the most controversial Q & A I have ever read. (click here) You can be assured that ICAP, the Illinois Appraisal Board and DPR will be reviewing the wording in this Q & A carefully.
Of special concern is the ASB's incorporation of new terminology found no where in USPAP;
“Comp Check Assignment”
“Full and Traditional assignments”
The Illinois Appraisal Board has made its position on comp checks very clear at past ICAP seminars. They MUST COMPLY with USPAP. The word comparable means a thought process must be implemented by someone to determine what compares. If it’s the appraiser, that's filtering folks!
A comp check is not the same as providing raw market data. An appraiser should be able to provide data to a client based on specific parameters provided by the client. In that case the word comparable could even apply, but it must be clear that it is comparable based on the client's parameters, not the appraiser's. If there is a value conclusion, whether it’s verbal or written, then you have just made an appraisal.
The second question in the July Q & A reads as follows:
I’m a residential appraiser and have been asked to perform a "comp check" (or "pre-comp") assignment, where a client wants to get an idea of the value of a home prior to proceeding with a mortgage financing transaction. Does USPAP allow me to perform this type of assignment?
How is the highlighted part of this question not a predetermined value issue? I feel the correct answer to this question should have been, “No, that’s not a comp check, that’s an appraisal”. I have no problem with the ASB providing direction to appraisers regarding services to clients, but the way this answer is worded will only add fuel to the COMP CHECK fire, not suppress it.
I have spoken with Brian Weaver, Director of the Appraisal Division of DPR, Bob Gorman, MAI, Chair of the Illinois Appraisal Board and Mike Maglocci, MAI, President of ICAP regarding the July Q & A. They also expressed their concerns regarding the wording in this document.
I would like to make it clear that the opinions in this alert are those of TJ McCarthy, SRA only and not ICAP, the Illinois Appraisal Board or the Department of Professional Regulation. Call it editorial privilege as webmaster.
Click on the following link to read the July Q & A - Download July_2008_QA.pdf
ICAP would like to hear from our members regarding these questions. You can send your opinions and comments to [email protected] and they will be forwarded to the ICAP Board and the Illinois Appraisal Board.
TJ McCARTHY AND ASSOCIATES, LTD.
Real Estate Appraisers and Consultants
7903 West 159th Street, Suite B
Tinley Park, Illinois 60477
Email: [email protected]
Phone: (708) 614.7200
Fax: (708) 614.7228
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