I have been a Virginia appraiser for over 25 years and I wish to comment on the use of hybrid appraisals. It appears to be self-evident that this proposal will produce substandard results which would undermine public trust.

Simply put, the hybrid product may generate a number, but there is no guarantee it is a supportable or verifiable. It is certainly not a USPAP compliant appraisal, and to call it such is misleading and a breach of public trust.

It is ironic that while most lenders do not accept reports in which inspections are performed by appraisal trainees (75 hours specialized training and under mentorship of licensed appraiser), the hybrid appraisal utilizes non-regulated data collectors who greatly influence the derived value.

The real issues at hand fundamentally seem to be whether Fannie/Freddie need or want USPAP compliant valuations at all, and why are they so willing to take such risks at the expense of the public?  The corollary questions are why are dummy-down valuations being considered at this time after the two decades of escalating requirements for appraisers? (Could it be AMCs are profiteering at the risk of jeopardizing the stability of the real estate market?) And why would this appalling approach be even considered by our regulators who are charged with protecting the public trust?

Or perhaps the recent real estate crisis never really happened?