The second paragraph in the Summary - AMCs section of the guidance document creates significant uncertainty about current board regulations by saying: "There is no law or Board regulation that expressly prohibits an AMC from providing property inspection data to an appraiser for use in an appraisal." While this is a true statement, the proposed guidance document would be much more transparent by including the VREAB Regulation from page 26, section C, number 1 of the current Real Estate Appraiser Regulations: "Therefore, no licensee shall sign or electronically transmit an appraisal which has been prepared by an unlicensed person unless such work was performed under the direction and supervision of the licensee in accordance with 54.1-2011 of the Code of Virginia."
A guidance document should provide clarity and transparency to licensees and users of appraisals. Personal interviews of industry participants and users of appraisals (realtors, loan officers, home inspectors, etc.) have revealed that most are not familiar with or have not even heard of a Hybrid Appraisal. There is significant bewilderment expressed as to why the appraiser profession has been limited in the use of Appraiser Trainees and in some cases mandated not to use them at all, yet the Hybrid Appraisal is being introduced as the modernization of the appraisal industry.
Please amend the Guidance Document to provide clarity, the document should include a definition of Hybrid Appraisal. It should also include instructions as to how a licensee can conform to current Board Regulations as stated on page 26, Section C - 1 of the Real Estate Appraisal Board Regulations while completing a Hybrid Appraisal.