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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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6/26/19  6:39 am
Commenter: Craig Morley, NAA

Bifrucated Appraisal Concerns
 

We have concerns about the use of a third party data collector being used to collect property data that will then be used in a decision matrix for making a loan and then having that information transmitted to an appraiser who is expected to rely on that information to complete a credible appraisal.

While  there is nothing  in USPAP that requires an appraisal to inspect a property, the appraise is expected to use information that they believe is credible. When a third party with questionable ethics and training is used, it calls into question the reliability of the data being collected.

Best practice under the Fannie Mae bifurcated appraisal model is to have the appraiser that would be potentially doing the appraisal to be engaged to go and collect the data, if  the property then requires and appraisal, the same appraiser would be engaged to complete the assignment. Under this model the appraiser completing the valuation would be responsible for the collection of the data to be used in the appraisal.

While other licensed professionals by be capable of collecting data for an appraisal, most do not have any specific training in accurately measuring the property, particularly on complex properties. My recommendation is that if someone other than an appraiser is to be used in the collection of the data, that a special license category be established where that person has a background check and has minimum standards completed to insure that they have the ability and knowledge to perform the data collection task. 

I believe sending unlicensed third parties with questionable backgrounds into homes puts the public at un-necessary risk and is a bad public policy to be allowed.

CommentID: 72726