Hybrid Appraisal Guidance Document
As stated in some of the other comments, this proposed guidance document is generic and just restates parts of the regulations without saying anything new. My past experience with guidance documents issued by Virginia for AMCs' shows me that AMCs' have legal teams that find numerous loopholes that allow the AMC to disregard the guidance document. Case in point was the guidance document concerning Reasonable & Customary Fees. I called the AMCs' that were my clients regarding the new guidance document. They had already found loopholes, mainly vague and open-ended wording, that allowed them to ignore the fees being paid for VA appraisals. Oh well, nice document, no meat. Back to Hybrid Appraisals, one of my clients has been pushing hard to get their independent appraisers to perform Property Data Inspections and Property Data Reviews without an opinion of value (which I now know are going to be used as hybrid appraisals). When they initially contacted me about my possible interest in performing these assignments, I was confused about the purpose of the reports. When I started asking questions about their purpose, they would not give me an answer. They actually told me that they did not know. This is the type of company that will be providing these services. Do we want the AMCs' to set the standards of Appraisal Practice instead of USPAP?