VaCAP received this informative newsletter from a member of our sister coalition, the Illinois Coalition of Appraisal Professionals late yesterday. VaCAP was the first state our appraisers these products may not comply with Virgina laws.We are aware of approximately 20 states in which there are conflicts between these products and state laws.
The Illinois Department of Financial & Professional Regulation has addressed hybrid appraisals in their IllinoisAppraiser Newletter. Some highlights, copied and pasted directly from the Newsletter:
“In Illinois, here’s what an unlicensed “inspector”, trained or not, can confidently provide to an appraiser:
Photographs? —Absolutely.
Improvement Quality? —No.
Improvement Condition? —No.
Room Count? —Even appraisers can’t agree on room counts (attics, add‐ons, three‐season rooms), or whether certain rooms are bedrooms or not (passthroughs). Improvement Size—Appraisers can’t come together on how to properly measure a structure. Are they rounding to the nearest foot? Half foot? No rounding at all?
In Illinois, filtered data needs to come from a licensed appraiser.
What about hybrids and AMCs in Illinois?
Registered AMCs certify to provide the following:
(225 ILCS 459/40) Sec. 40. Qualifications for registration. (6) a certification that the applicant will utilize Illinois licensed appraisers to provide appraisal services within the State of Illinois;
If it is clear that unlicensed inspectors are providing filtered data to appraisers, an appraisal service, then AMCs have breached this section of the Act and are subject to enforcement action. In its simplest terms, third party “inspectors” can tell an appraiser what they see; not provide their opinion of what they see.
In short, we’re not telling anyone not to provide hybrid reports; we’re just spelling out the consequences.”
See the entire article on the IllinoisAppraiser Newsletter.
The Virginia Real Estate Appraisal Board will discuss hybrid appraisals at the February 12 Board Meeting.
Thank you for being part of VaCAP!