What's a Director of Compliance?

If my mother were alive, she’d probably ask me what a Director of Compliance does for a living. I’m not sure how I’d respond. I suppose I’d say that I help ACI’s clients comply with the things with which they need to comply. Then she’d want to know what those things might be, and I’d answer USPAP, secondary market guidelines and specific client requirements. Then I’d get a funny look from her and the conversation would turn to another topic.

In short, what I do is help ACI view things from the appraiser’s perspective. But “Director of Compliance” sounds better than “Perspective Maintainer” and certainly looks better on a business card.

Joking aside, maintaining the appraiser’s perspective is essential to our company and to our clients. Having an appraiser on staff ensures that our products and services are truly appraiser-focused. So in this and future articles, we’ll look at what ACI has done and is doing to offer our clients the best.

One of my first projects when I returned to ACI (I was here from 1980 to 1991) was the GPAR™ (General Purpose Appraisal Report) family of forms. When Fannie and Freddie revised their appraisal forms in 2005, it was immediately apparent that using the new forms for non-lending work was awkward at best and USPAP non-compliant at worst. The form specifies the intended use as a mortgage finance transaction and the intended user as the lender client. This means that the (unmodified) URAR is not suitable for appraisals where the intended use involves divorce, estate, pre-listing, pre-purchase or any use other than lending. Yes, you can make countermanding statements or insert alternate pages 4-6, but the resulting report may look unprofessional and the end result is still presented on a form that:

• was designed for lending purposes
• carries a high level of attendant liability
• forces the appraiser to gather and report unneeded information

The GPAR forms were designed by ACI in response to our clients’ requests. Many clients wanted a general-purpose appraisal form that “looked and felt” much like the new URAR form and had a high level of data file compatibility to facilitate cloning between the general-purpose form and the URAR. 

Presently, the GPAR family of forms includes:

• GPAR-Single Family (2006)
• GPAR-Condo (2006)
• GPAR 2-4 (2007)
• GPAR-Land (2006)
• GPAR Flex (2007) RU SFR
• GPAR Flex (2007) RU SFR Grid
• GPAR Flex (2007) RU SFR Sm Grid

As the titles above indicate, we have general-purpose forms for single family, condo 2-4 family and vacant land. The last three, the flex forms, are designed to be used when the appraiser chooses to exercise the Restricted Use reporting option under USPAP. This seldom used reporting option can be a very useful tool that we’ll cover in a future installment of The Compliance Corner.

In the next installment, we’ll discuss the various GPAR forms, what they were designed to do and how you might want to utilize them.