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
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.