A client calls an appraiser asking for comp check. The client might or might not specify the subject property, but does indicate its bedroom and bathroom count, its size, its age, etc. The appraiser would then research recent sale's of home's with similar characteristic's of the request, but not analyze the data, nor form a value opinion based on it. The “client”, then, drew its own value conclusions. We already know that providing a value would constitute an appraisal and would require USPAP Compliance.

Many appraisers are uncomfortable with this, and needed to know if this practice would violate USPAP.  The answer to this question is on the August 2009 TAF Q&A.

Is an appraiser bound by USPAP for a particular assignment, when must the appraiser comply with the USPAP appraisal reporting requirements?

Whenever a value opinion is communicated, compliance with USPAP’s appraisal reporting requirements is required. It may seem obvious in many cases that an appraiser must abide by the appraisal reporting requirements. However, in other cases it is not as obvious, such as the following examples

Selecting and providing a client with comparable sales for a known property is an appraisal assignment as defined by USPAP.
Informing a property owner that their property tax assessment is too high is an appraisal report as defined in USPAP
Providing an opinion of market rent is an appraisal report as defined in USPAP.”

It appears that if a client or a potential client were to ask an appraiser for a list of comparable sales in a specific neighborhood and nothing more, the appraiser could provide this data. However, if a client or potential client were to specify either the subject property or the property type in that neighborhood, TAF would consider providing this data to be an appraisal and the appraiser would need to comply with Standards ONE and TWO of USPAP.

TAF has no authority to enforce appraisal law, it is governed by the individual states. Based on this decision and interpretation by TAF, it goes without saying that it will only be a matter of time before TAF will expect the states to enforce TAF'S decision.