Question:

My state appraisal board is asking me to send a copy of the workfile for an appraisal I performed eight years ago.  Since I provided no testimony in the assignment, I was only required to maintain access to the workfile for five years.  Given that this time period has expired, can the state board still take action in this case?

Response:

Yes.  The time frames referenced in the Record Keeping section of the ETHICS RULE are only minimums. Nothing in USPAP would prevent an enforcement proceeding from taking place after the applicable time period had expired.