NAR submitted comments to The Appraisal Foundation's Appraisal Standards Board (ASB) in response to its Exposure Draft: Proposed New Advisory Opinion (AO) 41, Use of Technology in an Appraisal or Appraisal Review Assignment.
In the letter, NAR reiterated its support for credible, independent valuations of real property, and emphasized that appraiser competency—as defined by the Uniform Standards of Professional Appraisal Practice (USPAP)—is key for credible appraisal results. The ASB's proposed AO addresses these issues, and the essence and guidance in general appears to be helpful in interpreting USPAP while using advanced technological tools.
However, NAR points out that some language in the AO may cause unnecessary confusion and asks for clarity to ensure that appraiser responsibilities are understood. Appraisers cannot realistically be expected to audit AI model architecture or inspect training datasets, as the current language suggests. Therefore, the appraiser's responsibility is to be competent to recognize when the tool produces an output that is unreliable—not the design, training, or underlying technology that produces this output.
Read NAR's comment letterpdf.