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Virginia Regulatory Town Hall
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Department of Professional and Occupational Regulation
Guidance Document Change: Providing guidance to real estate appraisers and AMCs on the use of hybrid appraisals
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6/5/19  8:34 am
Commenter: Peter Gallo

guidance document
 

I am a practicing appraiser in North Carolina and appraisers in our state as well as many others are tackling this issue of "hybrid" appraisals.  The GSEs are making the property inspection or as they call it, "property data collection", a separate function entirely from the valuation and completed by a non-appraiser.  These inspections, however, ARE being conducted for the purpose of being utilized in the development of a subsequent appraisal.  As such, it is a generally accepted concept that such inspections should be conducted by an appraiser or their trainee.  To develop a new, unregulated process appears to be an effort to circumvent licensing authorities and the responsibilities appraisers have to not only abide by credible and reliable development standards, but also to protect the public trust.  These are serious issues that need to be addressed as well as what would be considered "reliable" in light of the fact that these inspections are not public records from a reliable source, are not a homeowners opinion or report whcih an appraiser can understand the nature of.  These are inspections completed by actors that have various amounts of training, if any, and have no prohibition against bias, liability for misreporting or ignoring or enhancing items found on an inspection, etc.  They are also under no requirement to be licensed.  If there is any way that the Virginia Board, in their efforts to issue guidance, could address, it would be very helpful to other states and their appraisers.

CommentID: 72522