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Virginia Regulatory Town Hall
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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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6/24/19  11:26 am
Commenter: Renée Healion, SRA

The people of the Commonwealth deserve better
 

Some things do not make sense on their face. The GSEs have called for “modernization” of the appraisal process by eliminating appraisers from the process.  On the ground, the appraiser is the most efficient inspector. We have the comprehensive knowledge of the markets we are expert in. Further, the inspection adds to our store of knowledge.

In the proposed “hybrid” or bi-furcated model, the expert appraiser is cut off from the inspection and left to the writing of reports and stamping of their good name (and license and insurance). We appraisers, who would have to rely on the dubious quality of substitute inspectors, know this is where the danger lies for us. The danger for the consumer extends to the entire system.

Where are the savings in this model? Someone would have to be paid less for work we already do. Who will work for less than us? Appraisers are already left behind increases to keep up with inflation, so we manage. We increase our productivity by continually tending to our efficiencies. We are not the inefficient party in the loan process.

Our replacement in this scheme would have to be paid less. No professionals with transferable knowledge, such as home inspectors, would work for less. The new element of this model works for less because they know less. If they lack a license, they are not accountable to the public. Appraisers, alone, are accountable in this plan. We fear that the public will confuse these inspectors for us, and that the trust in appraisers will be damaged.

Who benefits? The parties who were backstopped by the US taxpayer. Surely, 2008 is not forgotten. Any savings in this scheme is done in the name of speed but it is money. Any monetary savings will not be passed on the consumer.

I appraise in Connecticut, but my mother has long resided in Williamsburg, Virginia. She is nearly 90. When she was worried about her property and I could not visit to see for myself, I asked a Virginia appraiser to look. It was not an appraisal, nor an interior inspection. Even for an inspection of the exterior of the dwelling, I thought to call a local appraiser. I knew I could rely on his expertise. The people of the Commonwealth should be able to rely on no less. Please do not further the use of this recent scheme.

 

CommentID: 72667