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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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6/19/19  8:47 pm
Commenter: James L Flynn, SRA

Hybrid appraisals are an unecessary and reckless fraud risk.
 

The property inspection is made by an unlicensed individual who could be tempted or paid to misrepresent property condition without any liscensing discipline.  AMCs will be motivated to utilize and pay inspectors that please loan originators by making positive property inspections which will effect property valuations by falsely increasing value. AMCs will have no liability and the inspectors no licensing discipline. Additionally the appraiser not having intimate knowledge of properties can lead to omitting important charachteristics that effect final valuation.

A poorly conceived and transparent attempt to weaken the lending discipline of a quality appraisal.

CommentID: 72609