3.2 The Appraisal Process and USPAP Basics
Key Takeaways
- An appraisal is an impartial appraiser's opinion of value; licensees cannot call a CMA or BPO an appraisal.
- The eight-step process moves from defining the problem through data, highest and best use, land value, the three approaches, reconciliation, and reporting.
- USPAP, from the Appraisal Standards Board of The Appraisal Foundation, sets minimum standards; the Ethics and Competency rules are most tested.
- Contingent fees tied to a target value violate the Ethics Rule, even if disclosed.
- Reconciliation weights the most reliable approach; it is never a simple average of the three indications.
Who Appraises and Why
An appraisal is an independent, impartial, objective opinion of value prepared by a licensed or certified appraiser. A real estate licensee is not an appraiser and may not call a CMA or BPO an appraisal. When a transaction involves a federally related loan, a licensed or certified appraiser must perform the valuation.
The lender, not the buyer, typically orders the appraisal to confirm the collateral supports the loan, even though the borrower usually pays for it. The appraiser owes a duty of independence to no party — the assignment is to the result, not to any client's desired number. Federal rules bar lenders from pressuring appraisers to hit a target value, a reform that followed the appraisal-inflation problems of the late-2000s housing crisis.
The Eight Steps of the Appraisal Process
The national exam tests the order of these steps:
- State the problem — identify property, value type, effective date, intended use.
- Determine data needed and the scope of work.
- Gather, record, and verify data (general market data and specific subject data).
- Determine highest and best use of the land as if vacant and as improved.
- Estimate land value separately.
- Apply the three approaches to value (sales comparison, cost, income).
- Reconcile the value indications into a single conclusion.
- Report the value in the agreed format.
Note that reconciliation comes near the end — it is never a simple average.
In the appraisal process, what does an appraiser do immediately after applying the three approaches to value?
What USPAP Is
USPAP stands for the Uniform Standards of Professional Appraisal Practice. It is the ethical and performance standard for appraisers in the United States, developed by the Appraisal Standards Board of The Appraisal Foundation, which Congress authorized to set appraiser qualification and practice criteria. USPAP is updated periodically and sets the minimum standards for developing and reporting an appraisal.
USPAP is built around several rules — the Ethics Rule, the Competency Rule, the Scope of Work Rule, the Jurisdictional Exception Rule, and the Record Keeping Rule — followed by Standards for various assignment types. Licensees should know the broad purpose, not memorize every standard.
Key USPAP Rules in Plain English
| Rule | What it requires |
|---|---|
| Ethics Rule | Independence, impartiality, no contingent fees tied to a target value |
| Competency Rule | Appraiser must have the knowledge/experience for the assignment or acquire it/disclose |
| Scope of Work Rule | Identify the work necessary for credible results |
| Jurisdictional Exception | If a law conflicts with USPAP, the conflicting part is voided, rest applies |
| Record Keeping Rule | Retain the workfile (commonly at least five years) |
The Ethics Rule is the most tested: an appraiser may never accept a fee contingent on reaching a predetermined value.
Appraiser Levels and the Three Federal Categories of Federally Related Transactions
Appraiser credentials generally rise in scope:
- Trainee/Licensed appraiser — simpler residential assignments.
- Certified Residential — one-to-four-unit residential, no value cap on complexity in many states.
- Certified General — all property types, including commercial.
For federally related loans, regulators set a de minimis threshold below which a full appraiser-performed appraisal may not be required and an evaluation can substitute. Know the concept, not a memorized dollar figure, since thresholds change.
Reconciliation: The Most Misunderstood Step
Reconciliation is the appraiser's analysis of the value indications from the three approaches to arrive at a single defensible opinion. It is weighting, not averaging.
Worked example: sales comparison = $305,000, cost = $330,000, income = $290,000. For an owner-occupied single-family home, the appraiser gives the most weight to sales comparison, some to cost, and little to income (few rentals), concluding perhaps $307,000. A simple average ($308,333) would be wrong because it ignores reliability. The most data-rich, applicable approach controls.
CMA, BPO, Appraisal, and AVM — Know the Difference
The exam contrasts four valuation products and who may produce them:
| Product | Producer | Typical use |
|---|---|---|
| Appraisal | Licensed/certified appraiser | Federally related loans, court, estate |
| CMA | Real estate licensee | Helping a seller set list price |
| BPO | Real estate licensee/broker | Lender short sale, REO, default review |
| AVM | Software/algorithm | Quick lender screening estimate |
Only the appraisal is a formal opinion of value under USPAP. A licensee who labels a CMA or BPO an "appraisal," or charges as if performing one, risks a license violation. Disclose the product's nature to clients.
Scope of Work and Credible Results
USPAP's Scope of Work Rule lets the appraiser, not the client, decide how much analysis an assignment needs to produce credible results — results worthy of belief given the intended use. The scope can range from a brief drive-by to a full interior inspection with extensive market analysis.
The related concept of an effective date anchors the opinion in time: value can be current, retrospective (a past date, common for estate or tax disputes), or prospective (a future date, such as completion of construction). A licensee preparing a CMA should likewise note the date, because a price opinion good today may be stale in ninety days as the market shifts.
The Eight Steps of the Appraisal Process
A credible appraisal follows an orderly sequence:
- Identify the problem (client, intended use, property rights, effective date).
- Determine scope of work.
- Collect data (general/market and specific/property data).
- Analyze highest and best use.
- Estimate land value separately.
- Apply the three approaches (sales comparison, cost, income).
- Reconcile the value indications into a single opinion.
- Report the value.
Reconciliation is not averaging — the appraiser weights the most reliable approach for the property type (sales comparison for homes, income for rentals, cost for new/special-purpose buildings).
USPAP, Highest and Best Use, and Appraiser Independence
USPAP (Uniform Standards of Professional Appraisal Practice) is the ethics-and-competency rulebook all appraisers must follow. Highest and best use — the use that is legally permissible, physically possible, financially feasible, and maximally productive — anchors the entire analysis; a property is valued at its highest and best use, not necessarily its current use.
Federal law (FIRREA and the Dodd-Frank appraiser-independence rules) bars anyone with an interest in the loan from pressuring an appraiser to hit a target value. This is why lenders order appraisals through independent channels. A licensee must never coach an appraiser toward the contract price.
An appraiser completes the sales comparison, cost, and income approaches with three different value indications. To arrive at the final opinion of value, the appraiser should:
An appraiser is offered $600 plus a $1,000 bonus if the appraisal supports the contract price. Under USPAP this is: