As appraiser in the Commonwealth of Virginia for over twenty years, I am concern with the use of electronic portals for the transmission of appraisal reports. It is my understanding transmission of appraisal reports are not being delivered in the original format, omission of portions of report and data in order the appraiser submitted.

Based on my understanding of USPAP Standard Rule 2-1. Standard 2-1 states " Written or oral real property report must clearly and accurately set forth the appraisal in a manner that will not be misleading; contain sufficient information to enable the intended users of appraisal to understand the report properly; and clearly and accurately disclose all assumptions, extraordinary assumptions, hypothetical conditions, and limiting conditions used in the assignment. ". If the report is not delivered to the client in the format, order of presentation of and/or omission of data and information provided by the appraiser, it can be a misleading report. The intended user (citizen of the commonwealth), has not been presented with the original report which maybe incomplete or misrepresented as the appraiser original work. The appraiser's integrity has been by jeopardized and the quality of his or her reporting. The intended user may now receive a report that is not creditable, misleading and incomplete due to the use of an electronic portal which alters the original report. The intended user has also mislead in believing the report they received is the complete report of appraiser. Furthermore, it is possible the altered report may not be in compliance with Standard 2-2, although prior to transmission by the electronic portal was in compliance.    

In addition to the possible violations of USPAP, these electronic portals are in direct conflict with the Commonwealth of Virginia Regulations 18VAC-130-20-180 C-1 Standards of professional practice. This regulations state “the signing of the report or electronic transmittal of the report shall indicate the licensee has direction and complete control over the report. Therefore, the electronic portal which changes or alters appraisal reports has made the appraiser or licensee in direct violation of state regulations.

The use of these electronic portals is putting appraisers in the Commonwealth in violations of the regulations governing appraisers in the Country (USPAP) and in the Commonwealth of Virginia. They have put undue burden on the appraiser and the ability practice as an appraiser. Furthermore, they are putting the public at risk and undermine the public trust by altering original appraisal reports. I strongly urge The Board to require the providers of electronic portals to cease in this practice and to insure the unaltered transmission of appraisal report to protect appraisers and the public in the Commonwealth of Virginia.

Respectfully submitted,