The proposed guidance document does not meet the definition of a guidance document in Town Hall. It merely restates the language in statutes and regulations in paragraph form. It fails to provide any meaningful direction, guidance or interpretation.
54.1-2009 defines an appraisal as an analysis, opinion, or conclusion relating to the nature, quality, value or utility of specified interests in, or aspects of identified real estate….
The inter-twine of statutes and definitions between AMC and appraiser statutes and regulations is confusing. Although USPAP does not require a physical observation of the subject, when one is completed for the purpose of obtaining information for an appraisal, common sense tells us it is part of the appraisal process and should be completed by the appraiser.
The VREAB is encouraged to remember why licensing of appraisers occurred after the savings and loan failures of the 1980s. FIRREA was passed to protect consumer trust in appraisal practice. Moving backwards with unlicensed activity defies common sense and logic. It is harmful to public trust, the housing market and the economy.
Appraisers have already heard stories from agents that the person coming to observe the property identities themselves as the appraiser. Allowing unlicensed, uninsured, unregulated individuals into a consumer’s home; walking through each and every room, poses a risk of safety to the consumer. What recourse does a consumer have if something goes awry?
Pressure on appraisers to complete these products is increasing and best practice is to address the concerns proactively, rather than through disciplinary actions. The VREAB is encouraged to provide meaningful direction and interpretation of the statutes and regulations they are charged with enforcing.
Thank You.