Does USPAP 2016 Require Paper Copies?

In the past two weeks I have received two emails from appraisers with essentially the same message, “So much for your love for paperless, Coach, because the new (2016) USPAP requires that appraisers keep hard copies of all delivered appraisal reports.”

What? Really? That did not sound right to me, and it turns out that it is not.

There are a few (not many) changes to the 2016-17 version of USPAP. One of them has to do with the recordkeeping rule. It
paperless-appraisal is that appraisers are required to retain in their workfile a ‘true copy’ of all appraisal reports delivered to a client. Actually, I am not sure this is a change so much as a clarification as this has always (at least the past few years) been something we have done in our office. Maybe we were just ahead of our time.

The confusion is around the term “true copy.” Some appraisers have misinterpreted that as meaning “hard copy” or “paper copy.” This is not a correct interpretation. The powers that be understand that many of us appraisers are paperless. There is no reason to roll back progress. As long as you have a digital copy in your workfile that can be readily accessed, you should be good to go.

As Gary F. Kristensen, SRA, IFA, AGA, said “USPAP uses the term “true” and not “hard” copies. A true copy can be a pdf of the appraisal. It just must be able to be accessed during the work file retention period and it must not be written over. This can be satisfied using pdf files and backup.”

The key here is that you do keep a copy (hard or otherwise) of each report that you deliver. If you change even a small thing, your new (and old) copy must be saved. You must be able to show each and every copy of each and every version of each and every appraisal report that you send out.


7 thoughts on “Does USPAP 2016 Require Paper Copies?”

  1. Every time a client and there AMC partner want some other bull crap statement added to the report, or that 10th sentence to explain what you’ve already described multiple times, its the appraiser who doesn’t get paid for his time and must keep track of the multiple variations of the same report (liability). They do not recognize our time, liability, understand USPAP guidelines and don’t care if they take 30 minutes of OUR TIME (why not, it’s free). Does anybody think they could ask their doctor, lawyer, accountant, mechanic, etc. to spend hours a month for free looking into something that has already been completed by the book?

  2. Total keeps a true copy for you in your work file evertime a revision is sent. And your digital signature has a different authorized number assigned for each report.

  3. No paper sounds good – as far as it goes. If someone disagrees with you so much that you get a subpoena requiring your workfile. A really nasty side effect of having everything in cyberspace or stored on a computer could conceivably be an a****le attorney who sees your computer hard drive as your file folder and requires full access to your machine. Then you have the option of an expensive fight to maintain confidentiality for your other clients, or you have a potential full data breach. Couldn’t happen, you say?? Why not?

  4. Robert E Powers

    Some AMC’s send my report thru an automated review, then as many as 3 paid reviewers and then sometimes I even get a post closing request to change something else. With storage space at a premium these days, the “Final Report”, is the only report I keep a “true copy” of. The rest are evidently just “rough drafts”. I still maintain a paper work file (and yes I have file cabinets and piles full of them) which includes a “true copy” of the report and that is the only thing I take to a deposition if needed. I make no excuses for still doing things the “old fashioned way”. They can have my clipboard and tape measure when they pry them from my cold dead hands…

  5. How is storage space at a premium? External drives are available at relatively low cost. I would hate to be brought before the board if they had a copy of a draft that I had not retained a copy of.

  6. One is well advised to keep a copy of every version of any appraisal report that leaves the computer. An initial report that is revised – for whatever reason, spelling correction, sketch revision, addition of comp or commentary – is a potential hangman’s noose. For example, a report sent might be might be sent without the prior service statement, and the appraiser, when asked, provides a revised report with the statement. The existence of the revised report with the compliant statement doesn’t obliterate the earlier, non-compliant, report. Viola! The appraiser now has two USPAP stumbles – a report without the prior service statement, and no “true copy” of the first report in her work file.

    Just my opinion –

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