IVS Additional Technical Revisions 2021
We have reviewed these proposals and submitted a detailed response, see below.
There are two significant changes proposed, but these do nothing to fix any of the problems in the existing standards and could actually make these worse.
The two significant changes proposed are:
To change the objective of the IVS from establishing “transparent and consistent valuation practices” to establishing “appropriate requirements for valuers”. This distinction is important because the role of establishing requirements for valuers, including whether they have to use the IVS for certain types of valuation, is a matter for government regulators or professional bodies.
To significantly extend the glossary. This now includes words or terms not used in the standards or necessary for their proper interpretation, as well as different words or terms for the same concept.
We see both these changes as creating unnecessary obstacles to the wider use of the IVS by narrowing their relevance to a few specific markets, and potentially creating conflict with bodies that have responsibility for regulating valuers.
Problems which have not been addressed include:
The redesignation of material that should be provided as guidance as mandatory or “presumptively mandatory” which is defined as an action that must be taken except in “rare circumstances”, and the reason for not taking it must be documented. Prior to 2017 the IVS included guidance designed to assist the understanding and consistent application of the mandatory material, but there was no suggestion this could be mandatory. It was recognised that there are often alternative ways in which the mandatory objective can be met, and the approach appropriate in one market may not be in another.
Confusion in the current standards between what is an “assumption” and what is a “special assumption” illustrated by a number of incorrect examples being included.
The consultation period is open until 30 April 2021. Whether you agree with our concerns or not it is important that you have your say.