Data entry – or data analysis?
The new URAR – using UAD 3.6 standards – is a way to fill up the GSE’s (Fannie/Freddie) database. Using appraiser appraisal output, the database will contain an extraordinary amount of information on every unit in America, if appraised by an appraiser or inspected by an unlicensed property inspector.
Allegedly, the appraiser is not liable for release of personal or confidential information. The new, mandated, appraiser certification allows the lender/client to “disclose or distribute this appraisal report to . . . data-collection or reporting services …” and “distribute the data in the appraisal report for internal or external purposes without having to obtain the appraiser’s or supervisory appraiser’s (if applicable) consent.” We will call this certification #25.
The possible conflict here is another certification – a part of USPAP, Ethics Rule, CONFIDENTIALITY. This section, also mandated by the GSEs, states “An appraiser must not disclose” (1) confidential information; or (2) assignment results to anyone other than the client, those authorized by the client, regulators, other “legal due process” third parties, and professional peer review committees.
Note that the GSE certification #25 above specifically includes “collection and reporting services.” Contrarily, the Ethics Rule requires “reasonable steps to safeguard access” to such information.
It appears this means once such a service has the report contents; anyone now becomes a candidate to receive those records from the collection and reporting service selling it.
As background, we need to keep in mind the underlying (technical) change in the URAR, (the Universal Residential Appraisal Report). In the past, the report itself was the object of discussion. The old ‘form’ mental state was that of a rectangular piece of paper which included facts, logic, opinion, and gathered work (such as pictures). While the old mental state continues, the forced thinking is clearly the new data-centric URAR, subject to UAD 3.6. This, in turn, is governed by MISMO, a naming standard, not a report standard. The old versus new thinking – identifies other, more detailed, issues below.
Some of these “info-points” are more than just that. information
Data is just that — until it isn’t. It does not become useful information until something happens:
- A question/problem/hypothesis is identified.
- The data is selected for possible exploration for usefulness.
- Your resulting information is ready for analysis, using the three basic predictive algorithms.
- The “report” includes elements of facts, logic and information, plus opinion and analytic results.
With UAD 3.6 URAR, we have individual pieces of points, curated information, applied models/algorithms/logic/reasoning, and interpreted/displayed results. The results themselves comprise different combinations of usefulness. These include regurgitated, selected, and validated data, analyzed processes, adjustments, opinions, model selections, algorithmic validations, plus summaries and explanations of graphs, summary statistics, organized tables, and accounts of reliability and reconciliation calculations. Whew!
We have a mix of data, information, analytics, displays, and professional opinion. Each of these may be differently protected as to property rights.
But note that Certification #25 only refers to “the data,” and may exclude all that other stuff.
UAD 3.6 is a data-entry construct. The appraiser’s analysis responsibility may be greater, not less!