A hybrid appraisal proposed guidance document has been posted for public comment.
As most of you know, hybrid or bifurcated appraisals are a very controversial topic currently. Virginia statutes and regulations have language which gives many of us pause on the compliance of hybrid appraisals as they are being presented in the industry. The Board has published a proposed guidance document in the hopes to clarify the language in our laws. Unfortunately, the proposed guidance document falls short of providing any meaningful guidance or clarification.
Per Virginia statute, the document has been published on Virginia Legislative Town Hall for public comments. At the end of the comment period, it is our understanding the Virginia Real Estate Appraisal Board will have an opportunity to revise the document prior to it being adopted by the Board for publication.
VaCAP has posted the comments below as an organization, however, we encourages each of you to add your own comments about the proposed hybrid guidance document as well. Take the time to really analyze the statutes and regulations that are impacted and make sure any doubt of compliance is addressed in your comments.
Public trust is at the forefront and consumer input is imperative. Please have a conversation with your friends and neighbors about hybrid or bifurcated appraisals. Ask them to comment. Not one consumer we are aware of has thought a hybrid of bifurcated appraisal was a good idea!
The comments are limited to 3,000 characters and the comment period ends on June 26, 2019. You can access the Proposed Guidance Document and comment here.
Thank You for Being Part of VaCAP!
An appraisal completed by a professional appraiser is the only independent part of the process of buying and selling real estate. A physical inspection by the person performing the appraisal is key to continuity and clarity.
A random person gathering information to submit to an appraiser will be completely misleading to the consumer. The random inspector is not at all responsible, including liability, but the appraiser is assuming the entire responsibility and liability although they have not physically entered the home. Many occasions I have inspected properties where there are “hidden” factors of a home, either improvements or deferred maintenance, that a random inspector with no training would miss. Are these random inspectors going to go into attics for FHA inspections? Measure accurately? Check for permitted or non-permitted additions, or deferred maintenance? These are items are only a small sample of what appraisers are trained to observe and report.
The hybrid process will not produce a credible product and will be very misleading to the consumer. They will not save time for anyone, nor money. Appraisers are trained to perform appraisals efficiently and at very reasonable prices and again we are the only objective entity in a real estate transaction.
Thank you for commenting. Please make sure you comment on Town Hall. https://townhall.virginia.gov/L/comments.cfm?GDocForumID=53