As a professional real estate appraiser this message should serve as a warning of the harm of having bifurcated appraisals involved in lending. Appraisers have had hundreds to thousands of hours of education and training to perform appraisals for mortgage lending.  The most critical component of the appraisal process is the defining and development of the subject property. Removing that process from the appraiser while having an unlicensed, unregulated, uninsured person performing that portion is not only reckless but it will have a long lasting ripple effect to the appraiser as they will be far removed from the market they are supposed to be an expert in.  They will be behind their desks not interacting with market participants observing and studying trends and neighborhoods. Please give pause and look hard at all implications and negative consequences this process could bring.  Thank you.