Agencies | Governor
Virginia Regulatory Town Hall
Agency
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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6/18/19  12:09 pm
Commenter: B.N. Appraisals, Inc

Was the appraisal inspection done by a criminal?
 

My concern is the inspections which these products require appraisers to rely on and the information provided.  At present, there is no standard for the inspection or whom preforms it, nationally or at a state level.  As realtors/brokers and lenders all have skin in the game, making money from a transaction; price and hitting that number are all they care about.  And the higher the price, the more the commission.  That is a double edged sword to both the consumer and the economy. 

Given this, I contend that the inspector must be competent in all aspects of the inspection, just as an appraiser is expected to be and that said inspector meet specific qualification standards and be licensed to “inspect”.  I contend that the person completing an inspection not be a realtor/broker involved in the transaction or form one or either of the offices involved in the transaction.  I contend the inspector not be in any way related to, or friends of the realtors/brokers involved in the transaction, or their offices and the inspector not be in any way related to, or friends of the lender involved in the transaction or that lending office.  Likewise of the buyer or seller.  And, having seen some photography of what we consider questionable (inspectors wearing shorts, tank tops, and questionable head gear), I contend the inspector should have a complete, fingerprinted background check to insure he/she is not criminally inclined or was not recently released from a prison or jail!

The inspection must remain an unbiased piece to the appraisal process and the person completing it must be knowledgeable and competent.  It might be easy to inspect a square or rectangle, but inspecting a 1905 Victorian with turrets, a English Tudor with dormers and half turrets, or a Neocolonial with large circular windows is far from easy and for the sake of value, accuracy counts!  So do we need an inspector with experience, or some guy off the street that just bought a tape measure and is being paid $75?  And, how long does this new cheaper fee stay cheaper???   

Only when the appraiser can trust the information he/she receives can the appraiser completing these modified appraisal products have some sense of confidence and relief that the information being provided in regard to the inspection is reliable enough to stake their reputation and certification on when they sign a report.  Because when spit hits the fan, no one is going to go looking for that person that did the inspection.  They are going to go after the person that signed the appraisal report; the appraiser.

In addition, at present, the lending community does not allow appraiser trainees to inspect real property without the direct supervision of a certified appraiser.  They fear the trainee, regardless of the number of years experience, is not competent enough to inspect unsupervised.  Yet, with this new appraisal product, using someone with no training or experience to inspect is a great idea?         

This is about protecting the consumer, the lender, the appraiser, and the economic future of this country and not about cheaper and faster!  And, the lending industry already has the qualified individual I have been referring to.  That qualified person would be an appraiser or an appraiser trainee.  

 

 

 

 

 

 

 

 

 

CommentID: 72595