Virginia Regulatory Town Hall
Agency
Department of Professional and Occupational Regulation
 
Board
Real Estate Appraiser Board
 
chapter
Real Estate Appraiser Board Rules and Regulations [18 VAC 130 ‑ 20]
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3/31/08  6:41 pm
Commenter: Richard Carmichael, RL Carmichael & Assoc Inc

Appraiser's Comment
 

As an appraiser, and appraiser instructor, I am concerned by the ability of lenders to force appraisers to utilize portal companies.

First, there is a concerted effort to force appraisers to use the "AI Ready" format, which takes data from the appraisal report and sends just the data.  This data is then reassembled and redistrubited to the lender.  One of the problems with this is that I as an appraiser have my signature applied to a document which I have lost control.  I know for a fact that not every field and and not every form transfers to this format.  I had a lender call me demanding that I provided information that was already provided.  It wasn't on her copy because the field is omitted.  This field was missing was the closing cost concesssions paid by the seller.  This is a material omission.  It can adversely affect not only the outcome of the loan underwriting, but the evaluation of me professionally because it make it look like I have forgotten to provide REQUIRED information.

My concern is that I am responsible for this document when I really have no way to control what is or is not omitted.  It is very possible that some of the omissions could seriously mislead a read a user of the report.

Secondly, I have concerns that confidential and copywrited information is being used to build AVM computer data bases.  AVMs are being used in place of appraisals in some cases, and some have even been marketed as appraisals.  Only a licensed appraiser may complete an appraisal report by law.

Third, some appraisal management companies are HEAVILY marketing Broker Price Opinions as appraisals, and these are being completed by agents who are receiving compensation for these when they are not the listing agents on the property.  This is also a violation of the law here in Virginia as recently noted but the Virginia Real Estate Board in their newsletter.

We are once again at a real estate crisis, some of which is being blamed on "faulty appraisals."  The S&L bailout of the late 1980s brought us licensing and reforms. 

Allowing 3rd party companies to strip data from reports, market BPOs, and allowing the use of AVMs has taken away the power of most of these reforms.

CommentID: 1305