Last Call to Post Comments of Town Hall

By | June 25, 2019


The time is almost up to post your comments on Town Hall concerning the Hybrid Appraisals Guidance Document. 

Virginia is on the forefront of the issue and the comments will help shape the Virginia Real Estate Appraisal Board’s decision concerning these products.

From what we have observed in the comments, public trust and credibility of the information being provided are the two main issues of the hybrid appraisal. Several have mentioned the next housing crash will occur as a result of the use of these products and we can not argue that point as it has significant merit. 

Appraisers, as each of you know,  are the only unbiased person within a real estate transaction and appraisers are licensed, regulated and held to the Uniform Standards of Professional Appraisal Practice. Allowing unlicensed, unregulated, unsupervised individuals to provide significant assistance goes against everything appraisers do and the intent of FIRREA. This is also a question of compliance with Virginia Statutes and Regulations.

VaCAP knows other states are watching Virginia closely and are ready to follow our lead. Lets make sure the Virginia Real Estate Appraisal Board has your thoughts so they can make the right decisions for these products.  

The deadline is June 26th @ midnight. 

Post your comment here.


Thank You for Being Part of VaCAP! 


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3 thoughts on “Last Call to Post Comments of Town Hall

  1. Bill McAree

    The fundamental tool for any appraisal is the ability to see the product (pick it up. look at it, smell it, see it).

  2. Brian R Woody

    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. The appraiser must get the intangible ‘feels’ of a house in order to determine what comps are appropriate to make a value determination. 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 appraiser to physically view the property. THERE IS NO SHORT CUT FOR 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, and the Dept. of VA work is much easier to complete with less interference.
    This proposed system will attract players to this industry that will attempt to manipulate the data and therefor the valuation of the collateral. There needs to be a professional, unbiased, third party to audit the collateral. In the event this proposed system is put in place, property value will increase sharply across the country until there comes a time that those artificial and manipulated values must be corrected to something that is reasonable, true, and well supported. These are basic economic principals that cannot be circumvented. ARTIFICIAL VALUES MUST 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.
    Thank you

  3. Robert Livingston

    Well put. Unfortunately, our appraisal board although they have posted the fees to be paid by the appraisers, they will not enforce them. I call ed them on several companies that were trying to get appraisals done for fees way below the fees posted by our board. The board told me that unless I accept the low fee, I can’t report them to have anything done. They went on to tell me that many appraisers that had been paid decided not to go forward so as not to be put on an exclusion list. Just the fact that we have the order sent to us on a low fee should be enough for our board to do something. Also, late payment is not being upheld by the board. If the company has anything in their contract about payment, then the boards 30 days payment goes out the window. How about the board watching out for their appraisers? One way is not to allow these hybrid appraisals from happening. Who do you think they will go after when the appraisal goes south? Only let licensed appraisers inspect the property and gather the information by doing a full appraisal and being paid a full fee. Not one that the fee is less the upload fee.


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