Agencies | Governor
Virginia Regulatory Town Hall
Department of Professional and Occupational Regulation
Real Estate Appraiser Board
Guidance Document Change: Providing guidance to real estate appraisers and AMCs on the use of hybrid appraisals
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6/18/19  5:13 pm
Commenter: Dave Williams

Damage to consumer protection

Having been an appraiser for over 20 years and having been active in the appraisal profession during the past real estate crisis, I find it appalling that this is even being seriously considered.  While there are many facets to putting together a reliable appraisal, I would venture to say that none is more important than the presence of a licensed and experienced appraiser during the inspection of the property being valued.  Appraisers have and continue to be heavily regulated and are required to stay up to speed through on going education and training.  Additionally, most appraisers currently practicing have many years of experience and gained knowledge of real estate and their specific market areas.  How could anyone possibly believe that turning the actual inspection process over to third parties that do not have to be licensed, are not regulated in anyway, do not have to be experienced or knowledgeable in valuing or inspection real estate, could not drastically reduce the reliability of the appraisal process and the final product provided to the consumer.  Home buyers deserve to have a professional appraiser INSPECT and develop the appraisals so they can have a reliable assurance of the homes value for making a purchase decision or a financing decision.  Even considering this is an assault on consumer protection and one that is related that the largest investment a person, typically, makes in their life.  Being licensed or certified, having many years of experience, having expertise in real estate valuation and your market area mean absolutely nothing if the inspection is going to be performed by someone who has none of these attributes or skills.  For the sake of the potential real estate buyers and consumers in general, I urge you not to even consider approving "hybrid appraisal", something that would destroy buyers protection by having their properties or potential properties INSPECTED by third parties who are not licensed, regulated, experienced or knowledgeable.  This would destroy the buyers most reliable protection in real estate purchases and I can see absolutely no positive benefits, certainly, none that would be worthy of the damage that this would cause the entire real estate purchasing process.  Please, let's learn from the past mistakes and not make decisions that would lead to an even worse real estate crisis, not to mention putting individual buyers in danger of making a bad decision due to inaccurate, misleading or inadequate data being provided by third party.  Let's lay this to rest and let the licensed professional appraisers get back to doing what we do best, protect consumers and lenders by providing expert reliable real estate appraisals.  Thanks

CommentID: 72598