From the organization that brought you the bat-shit crazy letter and the chickenshit letter, they are charging for classes that are misleading.

ASC just sent a letter to state appraiser regulatory officials pointing out that the USPAP update course is factually inaccurate and puts appraisers in legal jeopardy if they follow it.

Letter From Jim Park, Director ASC to State Appraiser Regulatory Officials: 2022-2023 7-Hour National USPAP Update Course

The letter references findings and recommendations found in the already presented report 6 months ago: Identifying Bias and Barriers, Promoting Equity: An Analysis of the USPAP Standards and Appraiser Qualifications Criteria

This is the meat & potatoes of the July 8, 2022 ASC letter:

ASC is essentially telling the 55 states and territories they don’t need to enforce this aspect of USPAP because the TAF course is inaccurate. In fact, the NFHA report that came out last January 2022 goes into specifics on why TAF’s effort is misleading. Yet TAF hasn’t pulled the USPAP class because it is their cash cow.

Why do we need a USPAP update class at all in this cycle? Key word here is “update” since we are in the third year of the two year renewal cycle “extended because of COVID” (lol), and we are still required to take the update class.

Let me summarize the situation for you:

Beyond that, TAF’s focus of the update class really is:

“How do I not get accused of bias?”

…rather than giving appraisers the tools they need to understand things like the difference between implicit and explicit bias.

Echoes of misleading

Does this situation sound familiar? It should. Remember when I called out TAF more than a year ago for their reckless use of the term “misleading,” because they doubled down by saying either “unintentional” or “intentional” misleading statements could place your license in jeopardy. They placed the appraiser on the hook in reference to the term “misleading” and are too lazy to take it out immediately until it is fixed or never put back in. How hard is that to do? How many minutes would it take to do their actual job on fixing the “misleading definition?” My wild guess would be 5-10 minutes.

As always, this addition to USPAP was done without legal review which is one of the core problems of the USPAP process. TAF has now brought in a law firm, but my goodness, this has been going on for more than three decades and the interpretation of “misleading” is still on the books?

For a small staff, this is an incredibly bloated institution.