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
Previous Comment     Next Comment     Back to List of Comments
6/19/19  5:23 pm
Commenter: Karen Emerle, SRA

RE Appraiser Board Proposed Guidance Document: Hybrid Appraisals

FIRREA was enacted to protect the public and ensure a minimum standard in appraisal practice. Where is the logic in allowing activity equivalent to actions prior to FIRREA?  Is this not steps backward? The inspection is the foundation on which all other aspects are built upon. If this is wrong, the entire report is wrong and the report has no credibility. No amount of disclosures, hypothetical conditions or extraordinary assumptions will change the fact the report is not credible. Virginia statutes and regulations are pretty clear and follow the intent of FIRREA; protecting the consumer from bad or fraudulent appraisals.


Public trust is also the focus of and in the preamble to USPAP.


Stated in the laws and regulations, the unlicensed assistance must be under the direct supervision of the licensed appraiser and the licensed appraiser completing the appraisal must have complete direction and control over the appraisal. Compete direction and control simply is not possible to obtain when an unknown third party is doing the inspection.


Virginia Statutes and Regulations are pretty clear. Please don’t be swayed by those who want to profit at the expense of the consumer by twisting the language and intent of the laws and regulations.

Thank you for reading and considering my comments.

CommentID: 72606