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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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6/25/19  9:32 am
Commenter: Eric Kennedy

Hybrids are a Public fraud
 

The Independent Appraiser has been under attack since the implementation of HVCC and the subsequent Dodd-Frank laws.  We were handed significant blame for the 2008 crash which was truly caused by Wall Street and Big Bank fraud.  There were plenty of rules in place in 2007 to control Appraisal fraud, however our Regulators (AARO.net) and State boards were doing very little to ENFORCE the existing laws.  So Dodd-Frank created a bunch of new rules that are ambiguous and abused by AMC's on a daily basis.  The AMC's and REVAA now believe that THEY are the Appraiser and are working feverishly to develop "products" that are faster and supposedly cheaper  - when in fact they are not.   And when in fact the true culprit in the "slow down" of Appraisals is the Appraisal OverManagement Companies now in existence and controlling at least 80% of FNMA lending work.  They send out each assignment for "bid" and will waste 7-10 days consistently "shopping" for a lower fee to maximize their profit margins.  NO regards are considered in each assignment other than "fee only" criteria....  no other competencies are truly considered. 

If you truly want quicker reports get the resources back to the Appraiser, a little job security and we can hire and train staff again and not be scattered and smothered by the Scope Creeps who keep dumping more work and wasting more of our time which has effectively destroyed our business model, much less be able to function efficiently and professionally. 

Tri-furcated Appraisals - (upgraded from Bi because the AMC is still an undisclosed participant in this fraud... ) is a completely non-Credible product which is only being used to dupe Joe Public out of the "Appraisal Fee" and provided with a completely worthless and non-Credible product.  They are no more reliable than a "Zestimate" and entirely un-defensable as a valuation product vs an experienced Certified Appraiser. 

Stop the madness and act like you got some sense

Sincerely

Barney Fife

CommentID: 72696