Jan 18, 2017 - 12:32 PM
Simply providing data such as all sales within a certain zip code in the last 12 months (without applying any adjustments or filtering of the data) would not constitute an appraisal. This concept is addressed in FAQ XX in the Frequently Asked Questions section of the 2016-17 USPAP publication as follows:
Question: I have a client that just wants me to provide comps from a neighborhood. Are there any USPAP requirements I must comply with to perform this task?
Response: To answer this question, it is important to identify exactly what the appraiser is being asked to do. If the appraiser is asked to provide comps that would typically mean the appraiser would be exercising his or her own judgment to determine which sales are most comparable to the subject property. The appraiser may choose to include only those sales that he or she deems are most similar to the subject in size, location, quality, or other relevant characteristics, which could mean that certain sales may be omitted. In this case, the resulting data would have been filtered by the appraiser’s judgment, which would have the net effect of providing a range of value to the client. This range of value is defined as an appraisal under USPAP; therefore, the appraiser would be obligated to comply with STANDARDS 1 and 2.
This should be contrasted to a request for an appraiser to simply provide data. For example, an appraiser asked by a client to provide sales data of all homes located within a one mile radius of a specific address could comply with the client’s request without complying with STANDARDS 1 and 2, as the appraiser would just be providing sales data pursuant to the client’s defined parameters. In this example, the appraiser must be careful not to communicate any opinions or conclusions regarding the data provided.
For related guidance on this topic, please see Advisory Opinion 19, Unacceptable Assignment Conditions in Real Property Appraisal Assignments.