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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4/4/08  1:12 pm
Commenter: Woody Fincham, FM & Associates Appraisal Services, INC

Appraiser's Comment
 

 

I can attest in all honesty that lighthouse changes my report from what I intend to send to what is converted. ACI’s Lighthouse can not convert other forms packages 100%. I receive constant calls from Underwriters and processor’s asking for pictures that get omitted, maps that are omitted, scanned in pages added as addenda (which often times contains very important data). It will move additional comments and bury things I want to stand out in a narrative box to the back of the report. 
 
FNC and the other portals out there should be required to deliver the exact copy of the report fully as intended by the preparer. I understand that some review is needed and merited by these types of companies, however the data pulled form there should be used for only that. Compiling that information beyond cursory review functions such as retaining for valuation modeling, market analysis, or comparable databases should be stopped and specifically prohibited. 
 
I am not sure what the Appraisal Board can do besides make it illegal for appraisers to do business with them, as the board can only recommend to the AG or other regulatory boards to regulate based on the concerns we are all out lining. I would assume that it may be in the best interest of the board to seek legislation to require all portals, and AMC’s operating in the Commonwealth to have a dedicated Chief Appraiser, and licensed or certified staffers that act as compliance officers/departments. If a company is found in non-compliance the individuals are punished and if applicable the businesses they work for should be severely penalized. You hit the companies where their wallets are and they will comply. 
 
I would think that the appraisal board would also benefit from having legislation drafted to require that lenders must be licensed, most especially the one’s involved with interacting with appraisers. If I need to have a number assigned to me that follows me the rest of my life as my license, then so too should the originators, underwriters and processing staff. We are asked to be held at special levels of knowledge, ethics and professionalism when any used car salesman can help a middle-class or low income family make financial decisions that will impact their ability to live within their means, or starve from being house poor. 
 
What may or may not come in the form of the HVCC can not be a consideration for what Virginia does, as that is far from being a steadfast and permanent rule. 
 
I am proud that what many of my peers have viewed as a stagnant board finally having the opportunity to not just follow what other more active state boards are doing, but to set precedent and lead Virginia into the future of what happens to my industry. If the board would see fit to set up a special task force to help these suggestion and some of the many I am sure you will hear, you can certainly count my name as a volunteer. 
CommentID: 1354