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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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6/26/19  1:22 pm
Commenter: Brian R Woody, First Colonial Appraisals

There is NO shortcut.
 

The essence of what an appraiser does is to act like informed buyers / sellers.  There is NOT a short cut that will ever be invented to replace the appraiser's PHYSICAL presence in a property.  There is NOT a typical buyer out there that would ever purchase a house under normal market conditions without physically being inside the property (including those pushing for this type of fake appraisal).  The residential appraiser MUST get the intangible 'feels' of a house in order to determine what comps are appropriate to make a value determination.  (Commercial appraisers may get away with only focusing on rents per square foot)  In the era of 'you cannot believe what you see in pictures' (and now videos) to be true, the only way to obtain a credible appraisal free from misinformation and intentional deceit is for the professional LICENSED / INSURED / FINGERPRINTED appraiser to physically view the property.  THERE IS NO SHORT CUT OF THIS.

There is NO appraiser shortage.  Each appraiser in my office can handle more work.  Our fees are exactly what the Dept. of VA quotes for their appraisals.  Unfortunately, this is not what the vast majority of AMC's and lenders are willing to compensate us for.  Further Dept. of VA appraisal assignments are less complicated and time consuming and involve less interference than AMC work.

This proposed 'split' appraiser system is not a case of two heads are better / cheaper / faster than one.  It will attract players to this industry that will attempt to manipulate the data and therefor the valuation of the collateral.  There needs to be ONE professional, unbiased, third party to audit the collateral.  An appraisal is not a democracy type system.  Someone needs to make the call and that person needs to have credible, self obtained information. 

In the event this proposed fake appraisal system is put in place (and unfortunately I fear it will be and these comments will fall on deaf ears) property values will increase sharply across the country until there comes a time that those artificial and manipulated values must be corrected to what is real and truthful and well supported.  These are basic economic principles that cannot be circumvented nor need to be modernized in this way.  ARTIFICIAL VALUES MUST AND WILL BE CORRECTED BY MARKET FORCES.  We currently have an appraisal system in place (Dept of VA) that is the model for the rest of the industry.  FNMA, FHA, and all of the others should adopt this system.  Please consider this alternative to what is being proposed. 

Further we have tried bifurcated appraisals in the past in the form of allowing the professional appraiser to train apprentices and therefor the next generation of appraisers.  Before the financial crisis, appraiser apprentices were allowed to inspect the property alone and the supervising appraiser was allowed to complete the assignment.  This worked wonderfully for appraiser firms as the principal appraiser personally trained the apprentice and accepted full responsibility for the report.  GSE's decided this was too risky and forbid this type of appraisal after the financial crisis so I wonder why now the pushers of this bifurcated proposal think this is a great idea once again.  

The vast majority of comments across the real estate industry (including agents and appraisers) are all the same...this is going to be a nightmare and will lead to mistrust of the appraisal process.  

Thank you 

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