To whom it may concern:

I have always been taught that it is the appraisers job to protect the public interest. We are trained to not MISLEAD the public. To be the eyes and ears of the lender so 2008 doesn't happen all over again.

It is in my humble opinion that Hybrid/Bifurcated appraisals will be catastrophic for the appraisal industry. Management companies are screaming there is a shortage of appraisers and they need these type of products. There is NOT a shortage of appraisers only a shortage of appraisers who are sick and tired of working for fees below what is considered customary & reasonable.

These appraisal management companies want to utilize independent contractors with minimal training. Send them out in the field to measure homes, offer their opinion on condition, quality and take photos. Provide that information to the signing appraiser who is supposed to develop an opinion of value for a significantly reduced fee. When I say reduced I meant to say $75-$100 per report and they are expecting them back within hours after the signing appraiser receives the information.

I've been a real estate appraiser for 19 years. There are homes to this day that are still challenging to measure. Are we just supposed to take the word of someone with minimal training that their word is gospel?  When they make a major mistake whose head is on the chopping block? Not theirs, because there is only one name on the report.

Third party inspector has no liability. No E&O. Not licensed with the state. Trained by the appraisal management company. Working for peanuts on the dollar with minimal training and we are just supposed to scribble our name on the report and assume all of the liability.

In closing I am vehemently against all Hybrids/Bifurcated reports. I do not feel that they best represent the interest of the industry. Within this industry you have good hard working licensed appraisers who have the ability to perform to the highest standards and provide quality reports in a timely manner.

We must protect the consumer.

Please reconsider the idea of misleading hybrid appraisals. They will adversely affect our profession and mislead the public.

Thank you

David

American Guild of Appraisers Member