Real estate appraisers are under siege by third parties that are desperately trying to replace our services with something more "modern." Yet appraisers understand the back story and know that there is no shortcut in providing credible valuation results. Hybrid appraisals are a systematic danger to the mortgage process and damage the public trust because they are:

- More expensive and slower to complete as they are parsed out to two different parties

- Removing the inspection from the valuation expert so it takes away the appraiser's familiarity with the property.

Just because something is "new" doesn't mean it is better.  Just because someone is against something proposed as "modern" like hybrids aren't stuck in the past.  Regulators are trying to create more loan volume because low mortgage rates are not effective.  They are trying to remove all pain points - providing a full appraisal is seen as a pain point yet appraisers are the only set of eyes left in the process to protect the consumer and the taxpayer against fraud.  Please consider this in your review of this matter.