AICPA, ASA and RICS open a principles-based successor to the Mandatory Performance Framework for comment
AICPA, ASA and RICS will take comments until Dec. 22, 2026 on a principles-based successor to the Mandatory Performance Framework. Its name drops the word 'Mandatory', so valuers now have to work out which of the old document's requirements still bind.
The Investor · Invest desk
What happened
- The sponsors released the exposure draft with a high-level bridging document that summarizes the key changes from the former Mandatory Performance Framework.
- Marianna Todorova, managing director at the Office of Professional Practice at Kroll, chairs the working group behind the proposed framework.
- The working group will review every comment before finalizing the framework, and no submission will be made public.
- Practitioners, users of valuation services, regulators and academics are invited to comment on the draft's clarity, operability, relevance and potential impact.
Why it matters
- decision Firms that depend on particular MPF requirements must argue for each one in writing, with rationale, before the window shuts, or take whatever version the working group settles on.
- constraint Users of valuations will get the final text with no public record of which firms or regulators asked for which changes.
- exposure Private-company auditors working to AICPA standards will be checking valuations prepared under a framework the same institute co-wrote.
The way the sponsors describe the draft goes some way to explaining the new name [15]. They call it comprehensive and principles-based, designed to promote consistency, quality and transparency across valuation engagements [3]. The release says it keeps a commitment to "professional competence, objectivity and sound professional judgment" [14]. It also says the draft builds on the foundation of the old Mandatory Performance Framework [4].
A rename can mean little or a lot. If it is cosmetic, the old requirements carry across with their force intact, and the bridging document [8] lists mostly drafting edits. If some requirements have become principles, the question of whether a valuer did enough stops being a checklist. It becomes a judgment that an auditor or reviewer makes one engagement at a time. The working group can also change the draft after it reads the comments [9]. In my view the second outcome is the likeliest, because a text organised around principles and professional judgment [3][14] has less room for line-item rules than one titled "Mandatory" [15]. If the bridging document shows the old requirements carried over unchanged, that view is wrong [8].
Todorova said the change was a response to the market. "The valuation profession continues to evolve in response to changing market demands, regulatory expectations and stakeholder needs," she said [5]. She said the sponsors "encourage broad participation in the review process" [7].
The letters stay sealed [9]. The best case for sealed letters is candor: a valuation firm can criticize a draft rule in a letter its clients and competitors will never read. The sponsors want each letter to carry specific recommendations and supporting rationale [12]. Letters go to VPFConsultation@rics.org or to named contacts at the AICPA, ASA and RICS [10].
What to watch
- The final text, and whether any of its requirements still bind the way the old document's name implied.
- Whether the sponsors set an effective date and transition period when they finalize the framework.
- Any published summary of comment themes from the working group, even though individual letters stay sealed.
Clarity's read
What the record supports and how the coverage leans. The claims behind it follow.
Reality
- Evidence50
- Adoption
- Insufficient
- Hype gap+15
- Incentives65
- Confidence60
Claim ledger
Ranked by verification strength, evidence, and original report placement.
- [1]
The AICPA, the American Society of Appraisers (ASA) and the Royal Institution of Chartered Surveyors (RICS) are seeking comment on an exposure draft for the proposed Valuation Performance Framework (VPF).
- [2]
The public comment period runs through Dec. 22, 2026, and comments should be submitted no later than that date.
- [3]
The proposed VPF has been developed as a comprehensive, principles-based framework designed to promote consistency, quality and transparency across valuation engagements.
- [4]
The framework builds upon the foundation of the document formerly known as the Mandatory Performance Framework (MPF).
- [5]
"The valuation profession continues to evolve in response to changing market demands, regulatory expectations and stakeholder needs," said Marianna Todorova.
- [6]
Marianna Todorova, managing director at the Office of Professional Practice, Kroll, is chair of the Valuation Performance Framework Working Group.
- [7]
"The proposed Valuation Performance Framework represents an important step toward strengthening consistency and confidence in valuation practice across the profession, and we encourage broad participation in the review process."
- [8]
The organizations released the exposure draft and a high-level bridging document that summarizes the key changes between the former Mandatory Performance Framework and the proposed VPF, to be reviewed alongside the full exposure draft.
- [9]
All comments received during the exposure period will be reviewed and considered by the VPF Working Group before the framework is finalized. No comments will be made public.
- [10]
Comments go to VPFConsultation@rics.org, or directly to Mark Smith (AICPA), Bonny Rogers (ASA) or Steve Choi (RICS).
- [11]
The AICPA, ASA and RICS encourage practitioners, users of valuation services, regulators, academics and other interested parties to comment on all aspects of the framework, including its clarity, operability, relevance and potential impact on valuation practice.
- [12]
Respondents are encouraged to provide specific recommendations and supporting rationale to help inform the evaluation of proposed revisions.
- [13]
The AICPA sets ethical standards for the profession, attestation standards, and U.S. auditing standards for private companies, not-for-profit organizations, and federal, state and local governments.
- [14]
The VPF reflects the evolving needs of valuation professionals while maintaining a commitment to professional competence, objectivity and sound professional judgment.
- [15]
The successor's name drops the word 'Mandatory': the Mandatory Performance Framework is succeeded by the Valuation Performance Framework.
- [16]
Because no comments will be made public while practitioners, users of valuation services, regulators and academics are all invited to respond, no respondent group can see what another asked for, and users receive the final text without a public record of who requested each change.
- [17]
The AICPA co-sponsors the proposed valuation performance framework and also sets U.S. auditing standards for private companies.
Sources
1 independent publisher whose own reporting we read for this story.
- cpapracticeadvisor.comAICPA, ASA and RICS Seek Public Comment on Proposed Valuation Performance Framework
1 article · October 8, 2026
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