Chief Operations Officer’s Report: Regulatory Pronouncement—First Quarter 2026
Regulatory Pronouncement: NACVA Comments on Exposure Drafts Issued by The Appraisal Foundation
Brien K. Jones
Chief Operations Officer and Executive Vice President of Business Development
On January 2nd, The Appraisal Foundation's (TAF) Appraisal Standards Board (ASB) issued the First Exposure Draft: New Advisory Opinion 41, Use of Technology in an Appraisal or Appraisal Review.
It proposes to modernize the Uniform Standards of Professional Appraisal Practice (USPAP) guidance on technology used in appraisal and stresses that tools assist but never replace appraiser judgment. Responsibility for ethics, competency, scope of work, credibility, confidentiality, and reporting remains with the appraiser, and older technology advisory opinions would be retired.
NACVA’s comments agree with this framework, support retiring older technology opinions, but highlight interpretive risks, especially around intent-based ethics language.
NACVA also urges the ASB to clarify that USPAP is not the default governing standard for all valuation engagements, recommends greater acknowledgment of recognized professional standards, particularly in business valuation, litigation, and financial reporting contexts that are governed by recognized professional standards that align with practical business valuation and forensic practice.
On February 19th, the ASB will discuss comments received at its virtual public meeting.
- Read the comments submitted by NACVA
- Read the NACVA Advisory Brief on The Use of Artificial Intelligence and Machine Learning
On January 5th TAF’s Business Valuation Resource Panel (BVRP) issued the First Exposure Draft of Proposed Changes to Valuation Brief #4: Is the Business Appraiser You Intend to Hire Competent for the Assignment?
Grounded in USPAP, it serves as a guide to explain appraiser competency, emphasizes assignment-specific competency, and early identification of intended use, limits credentials and software, and practical methods—such as interviews—to evaluate appraiser suitability.
NACVA’s comments support the brief’s emphasis on assignment-specific competency, professional judgment, and intended use. However, it cautions against overstating the universality of USPAP, urges acknowledgment of recognized professional standards that align with practical business valuation and forensic practice, and seeks stronger emphasis on credentials, disclosure, and assignment refusal when competency limitations exist.
The Association's Governance Task Force wrote and submitted comments on both exposure drafts on behalf of the Association's global membership and credential holders.
“NACVA submitted formal comments on both exposure drafts because they address fundamentally different, yet equally critical, issues affecting valuation practice,” states Pasquale Rafanelli, CPA, ABV, CVA, CBA, MAFF, ASA, CFE, CDFA, AEP, and chair of NACVA’s Standards Board. “The proposed Advisory Opinion on technology and artificial intelligence raises questions of professional judgment, ethical responsibility, and accountability that go to the core of public trust in appraisal work, particularly as automated and AI-driven tools become more prevalent in valuation engagements. Separately, the proposed revisions to Valuation Brief 2025-4 implicate how competency is understood and evaluated in business valuation assignments, including the risk that readers may incorrectly assume a single governing standard applies across all valuation services. In both cases, NACVA believed it was essential to provide clarity to ensure the guidance strengthens—not inadvertently distorts—professional standards and public understanding.”
“As technology and AI rapidly reshape the valuation landscape, our standards must reinforce a foundational truth: these tools are aids to, not replacements for, professional judgment,” states Nainesh Shah, CFA, CVA, chair of NACVA’s Artificial Intelligence and Machine Learning Commission and member of its Executive Advisory Board. “Our comments ensure that appraisers remain the ultimate stewards of credibility and ethics, maintaining public trust even as we embrace the efficiencies of modern innovation.”
The Association extends appreciation to the members of the Governance Task Force who championed this initiative.
NACVA Executive Advisory Board
Chair: Christina LoRusso, MSA, CDFA, CFE, CVA, MAFF
Parnell Black, MBA, CPA, CVA, NACVA CEO
Brien Jones, NACVA Chief Operations Officer and Executive Vice President
Mark Kucik, CPA, CVA, CM&AA, CFF, CPVA
NACVA Artificial Intelligence and Machine Learning Commission
Chair: Nainesh Shah, CFA, CVA
Lorraine A. Barton, CPA, ABV, CFF, CIRA, CVA, MAFF, MBA
C. Zachary Meyers, CPA, CVA
Pasquale Rafanelli, CPA, ABV, CVA, CBA, MAFF, ASA, CFE, CDFA®, AEP®
NACVA Ethics Oversight Board
Chair: Steven McDonald, CVA
Lorraine A. Barton, CPA, ABV, CFF, CIRA, CVA, MAFF, MBA
James Ewart, CPA, ABV, CFF, CVA
Scott Saltzman, CPA, CVA, ASA, ABV, MAFF
NACVA Leadership Initiative Board
Chair: T.J. Liles-Tims, MBA, CVA, CFE, MAFF
Mark Kucik, CPA, CVA, CM&AA, CFF, CPVA
Tonisha Pinckney, PhD, MSCJ, MAFF, CFE, CBE, CSCD, CCII
NACVA Standards Board
Chair: Pasquale Rafanelli, CPA, ABV, CVA, CBA, MAFF, ASA, CFE, CDFA®, AEP®
C. Zachary Meyers, CPA, CVA
Mark Kucik, CPA, CVA, CM&AA, CFF, CPVA
Visit www.NACVA.com/Standards to access useful professional standards tools.
