Tuesday, April 10, 2018

Ask an Instructor: Requal Exams and USPAP Required Disclosures

ISA members are invited to send in their questions on all things appraising and education to ISA's instructors. One of ISA's instructors will share answers on the ISA Now Blog. Please send questions to directorofeducation@isa-appraisers.org.


Question: Is there an exam for Requal?

Answer: No, there is currently not an exam component with the Requalification course. ISA's policy is that all members must "requalify" every five years. In order to fulfill the Requalification requirement, you must successfully complete the course (either onsite or live online), submit a federal function appraisal report for peer review during the course, and submit the completed Requalification packet within 45 days of completing the course. More information on the ISA Requalification Process can be found here. If you should have any specific questions about your Requalification with ISA, please contact ISA headquarters at isa@isa-appraisers.org for more details. Need to requalify? Register for the next Requalification course here.

Editor's note: The following question comes from the March 29, 2018 USPAP Q&A and has been adapted to pertain to Personal Property appraisals.

Question: I am using an appraisal form that has an appraiser's certification which cannot be altered. The certification does not include USPAP's required disclosure on whether I performed any services on the property in the three years prior to the assignment. May I simply add such a statement elsewhere in the report, outside of the certification?

Answer: No. Simply adding information in the body of a report is not the same as a signed certification. Any supplemental certification should be clearly identified, and it must be signed as required by Standards Rule 8-3.

USPAP does not require the report to be signed; it requires a signed certification. USPAP acknowledges that signatures may appear elsewhere in the report, and if so, per the Comment to Standards Rule 8-3, any party signing elsewhere must also sign the certification. NOTE: ISA requires that the report be signed. Thus, if your certification statement is the last item in your cover document, then you can sign your report and the certification statement with one signature. If your certification statement is elsewhere in your document, then you need to sign the certification statement page and also the report itself – remembering that anyone who signs the report must also sign the certification.

While USPAP does not require labeling the certification with that specific term, the certification must be similar in content to the language in USPAP's Standards Rule 8-3, which starts with "I hereby certify that..." The Comment to Standards Rule 8-3 states that a "signed certification" is an integral part of the report, but it is a clearly differentiated part of the report. For example, it may be difficult for an appraiser to defend a statement on page 18 of an appraisal report as being a "signed certification" when the only signature is on page 6 below a list of items clearly labeled an Appraiser's Certification.

- Meredith Meuwly, ISA CAPP
Director of Education

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