Posts Tagged ‘GAAP’
Appraisal Institute meeting in San Diego
I had the pleasure of being invited to speak at the Appraisal Institute’s annual meeting in San Diego last week, which brought together many of the top minds in the valuation field for three days of seminars and business meetings. While AI is fairly small (only about 23,000 members globally), its influence in the real estate field cannot be understated. In the U.S., appraisal license law and standards (the Uniform Standards of Professional Appraisal Practice, commonly known as USPAP) owe their genesis to work done by AI back in the 1980’s during the Savings and Loan Crisis, and possession of an AI designation (either MAI or SRA) is frequently cited in real estate contracts as required for establishing lease renewal rates or other contractual matters. Courts throughout the land routinely accept testimony from AI members without question. Real estate regulatory bodies throughout the U.S. are populated by AI members, and rare is the state legislature that will make changes to real estate law without the consultation of AI members. The AI’s government affairs team in D.C. has influence throughout the real estate arena, which of course today transcends traditional boundaries and includes regulatory efforts of the GAO and SEC, among others.
I was asked asked to deliver an address on advanced statistical methods. I’ll leave that discussion for another day, and focus on what I learned there — which was significant — rather than what I said. Other sessions dealt with meaty topics like the attorney/appraiser interface and the complexity of real estate valuation in the financial reporting arena. Not unexpectedly, there was a tremendous amount of attention paid to technology, which is really leading to an interface between “automated valuation model”-type tools and the individual appraiser. In short, we may be very close to a day, thanks to technology, when the individual home appraiser is tapping into a more robust set of analytical tools in order to produce collateral valuations with strong statistical support. Anyone who has been following the mortgage meltdown news for the past few years will understand the significance.
The keynote speaker was Dylan Taylor, CEO/USA of Colliers International. He riffed off of the title of the book “The Earth is Flat”, and talked about barriers to globalization in the real estate biz which he called “rounders”. The two principle ones for our field are regulatory barriers (licensure problems, even across 50 states, much less across countries) and capital needed to grow businesses (technology, etc.) He notes that in most professions, there is a tipping point to consolidation, and uses CPA firms as examples. The total billings of U.S. CPA firms last year was about $120 Billion, and the big 4 accounted for $80 Billion of that. The need for technology, increased specialization, etc., will probably stimulate that in appraisal firms (which currently have world-wide billings on the order of $3 Billion, but the top few only account for a small fraction of that). He says that in the future, there will be a handful of very large appraisal firms plus “boutiques”. In his view, the boutiques will do quite nicely, but the middle-market appraisal firms will die on the vine.
Taylor notes that USPAP will be generally moving toward International Valuation Standards (“IVS”) in the same way Generally Accepted Accounting Practice (“GAAP”) is moving toward International Financial Reporting Standards (“IFRS”). The latter sets of standards provide much more “client defined” reporting standards. He notes, for example, that several aspects of IFRS will cause “disruptive change” in American real estate, such as the way the two different paradigms treat carried interest.
As noted, a separate session dealt with the interface between appraisal and financial reporting. Earlier this year, the SEC “kicked the can” toward 2013 for U.S. adoption of IFRS. It was noted that while 90% of GAAP and IFRS are functionally identical, the changes needed to adopt the remaining standards could be so costly and disruptive as to dwarf the problems following adoption of Sarbanes-Oxley. Nonetheless, some movement in that direction is inevitable. From a real estate perspective, this may include the elimination of depreciation for financial reporting, substituting annual “mark-to-market” valuations instead. That is a very different paradigm for property valuation in the U.S.
Other sessions included a presentation from the FDIC’s General Counsel’s office, a presentation on standards and practices for Federal land acquisition, and a VERY informative presentation on “getting published”.
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International Financial Reporting Standards
I know I’m sounding like an overly technical geek on these subjects, but as we know from the recent (current?) economic malaise, seemingly back-page issues can have major impacts on large segments of the economy.
Buried deep inside Friday’s issue of the Wall Street Journal (OK, page C1, but that’s pretty deep) was news that the SEC will once again delay implementation of the International Financial Reporting Standards (“IFRS”) for U.S. regulated businesses (from a practical standpoint, essentially all of them). For those who aren’t up on their accounting theory, U.S. accounting standards — generally referred to as “Generally Accepted Accounting Practices” or “GAAP” for short — have been developed over time from essentially three sources: “best practices” which have evolved literally over the centuries, pronouncements of the Financial Accounting Standards Board, or “FASB”, and its predecessors, and adaptations to conform with U.S. tax practice. IFSR is more of a top-down approach, and governs accounting practices pretty much anywhere in the developed world EXCEPT for the U.S. (One might argue, and with some validity, that recent accounting problems among Chinese businesses reveal real problem with IFRS compliance, and one wouldn’t be altogether wrong. That’s a topic for a different day, though.)
American businesses dealing in global commerce (as nearly all big ones do, now-a-days) have been anxious for a unifying accounting paradigm for many years. Indeed, the differences between IFRS and GAAP are significant, and in fact adoption of IFRS in the U.S. may cost many businesses quite a bit in tax penalties, since IFRS doesn’t recognize certain tax avoidance strategies (e.g. — last-in-first-out inventory accounting) that are common in the U.S. Nonetheless, American businesses are willing to suffer the tax pain in order to get a common accounting language globally.
From an accounting perspective, this delay by the SEC is a royal pain in the neck, but that too is a topic for another day. The reason I bring it up today is the implicit impact on real estate appraisal standards. I’ve noted, with some interest, that appraisal standards are increasingly derivative of accounting practices. Back when America’s Uniform Standards of Professional Appraisal Practice (“USPAP”) was developed, accountants could barely care about appraisal standards. Today, a close examination of the International Valuation Standards Council (IVS) reveals a substantial degree of input from the accounting and banking fields, much more than we saw 25-ish years ago when USPAP was first codified.
In my own observation, this SEC delay gives the appraisal profession another year or so to decide if they want a top-down or bottoms-up approach to appraisal standards in the U.S. Do appraisers want to be driving the truck or riding in the back? I’ve observed that the three constituent “regulatory” bodies (the professional organizations, such as the Appraisal Institute and RICS, the Appraisal Foundation, and the state and federal regulators) seem to be of three different minds on the subject. The constituent bodies seem to be more proactive and ready to move forward with IVS adoption. The Foundation seems to have been constantly playing damage control in the past couple of years over the mortgage market meltdown and the resultant sturm-and-drang from the Federal regulatory bodies. None of those regulatory bodies seemed to have a dog in this hunt, so haven’t appeared to care. I will say, however, that proposed changes to USPAP 2014, which are currently being circulated in draft form, are very forward-looking, albeit with baby steps.
Finally, state regulators are almost 100% reactive. Some are very good at reacting, and some are very bad. Currently, they are all overwhelmed with the double-whammy of very real budget cuts and very real appraisal standards violations problems emanating from the mortgage market meltdown. As such, a major paradigm shift in appraisal standards will be difficult for them to swallow.
This all seems to be back-page stuff, but in fact these issues have very real implications for the way “business does business”, particularly in the real estate valuation world. We’ll keep you posted.
From a small northwestern observatory... 