Agencies | Governor
Virginia Regulatory Town Hall
Department of Professional and Occupational Regulation
Real Estate Appraiser Board
Guidance Document Change: Providing guidance to real estate appraisers and AMCs on the use of hybrid appraisals
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6/25/19  9:31 am
Commenter: Carrie Lloyd

Hybrid assignments NOT appraisals

I am a boots on the ground professional real estate appraiser within the state of Michigan and the use of hybrid/bifurcated appraisals should not be utilized. To have to rely on anothers inspection of the property is crazy. As an appraiser you have no idea what that inspectors training and education has been. While the GSE's don't care that these people are qualified the appraisers do because we are the ones that are required to sign off on the appraisal and value it based on someone elses view. Appraisers have had hundreds to thousands of hours of education and training to perform appraisals for mortgage lending and the most critical component of the appraisal process is the defining and development of the subject property. To remove that process from the appraiser while having an unlicensed, unregulated, uninsured person performing that portion is not only unprofessional but it will have a long effect to the appraiser and the homeowner. Homeowners should not have to carry this burden of someone entering their house with no qualifications. Appraisers were put in place for the checks and balances within the industry and the most important part of the process is (IMO) the inspection of the home as pictures don't do justice- look at agents MLS pictures then go to a property- they are completely different as the agents portray the home they want you to see not necessarily the way the home actually is. The use of these products need to be analyzed by someone within the profession and not law makers who have no idea on the correct process of valuing a property. The negative consequences will prevail and unfortunately the ones who will suffer are the homeowners and the appraisers as this process will benefit only the lenders and then what happens when the market crashes again( which it will and using these products it will come earlier than later). Will they get bailed out again? I hope not as they need to have skin in this game also besides just the consumers.   Thank you for the opportunity to comment on this issue.

CommentID: 72695