I am asking the board to limit the use of these products in the State of Virginia. I am a licensed appraiser Virginia, and consider myself a stakeholder with regard to appraisal practices in this state. My comments are specifically referring to an appraisal where the interior inspection is performed by a person other than the appraiser performing and signing the appraisal report.

If an interior inspection is required for the scope of work of the assignment, the responsibility should lie with the individual appraiser to ensure that condition is met. Why are third parties, licensed or not, who are not affiliated with the appraiser, being used in appraisals that in effect, require the appraiser to NOT inspect the interior of the subject property when the scope of work calls for an interior inspection? Is this wise? Does this even make sense?  

How can an appraiser know that the third party inspector is unbiased, is competent, is ethical, and has no interest in the subject property? 

These products are bad news. They remove control of data from being gathered by the appraiser, to being provided to the appraiser, by a source unknown and unverified by the appraiser. If a third party inspection is going to be a requirement for the scope of work of the appraisal, the appraiser should engage the inspecting party, or have control over the inspection, as the appraiser is ultimately responsible.

Will future appraisal products contain market conditions sections that are provided by the client, auto-filled by third party data companies, and have a scope of work requiring the use of the third party market data, chosen by the client, to be in the report? If this were happening today, would it be allowed?