The problem today is the ever increasing ‘direct’ obligations placed on appraisers by the order / Letter of Engagement to personally inspect. It ceased being so much of a lender concern as a competitive ‘benefit’ of using XYZ AMC over ABC AMC. The former might advertise “an all certified appraiser panel and require onsite inspection by THAT specific appraiser.” Its a huge time burden to overcome when I have to personally inspect the property (as I ALWAYS do). Clearly it limits my income. It also acts as a disincentive to take on trainees.

MANY in our profession simply ‘cheat’ in this area. They’ve simply chosen a business model under which they LIE to the clients about who inspected the property. In fact, once they decide to lie its almost safer for them to have NON APPRAISERS with no licenses to lose, do the inspections using lots of pictures as you noted. We all either know of or have heard of those that operate this way. No wonder so many don’t fight over C&R fees. They are paying $75 to $125 for someone else to inspect the property an taking $175 to $225 for themselves to write up reports without ever seeing the property!

Dustin is not in any way suggesting the dishonest practice would ever be acceptable. What he is suggesting is AUTHORIZED use of qualified trainees.

Such use would have to be ‘free’ and flexible enough to be economically viable as a business model. The second the lenders or underwriters step in to micro manage the process, we will be right back on the same road that lead us to doing away with trainees in the first place. Let US decide when an appraiser or trainee is competent to inspect on their own. We are placing OUR reputation on the line when we co sign behind them.

While I’m still skeptical of “big data” (like the FNMA CU database that they ADMIT is built on data that was wrong), the practicality of Dustin’s solution could in fact revitalize our entire industry. It could help keep fees lower for lenders and AMCS (Did I just say that???), by allowing the honest appraisers to legally & properly do what the dishonest ones are already doing. It shouldn’t keep fees down to $350 or $400 but it might keep them down to $500 or so.

The real problem is that until a major GSE or regulators specifically AUTHORIZE use of qualified licensed trainees to do the inspections without supervisory onsite oversight inspection nothing will happen to this common sense suggestion.

FNMA, FreddieMac, VA, FHA, FFIEC, the ball is in YOUR court. A simple one paragraph addition to guidelines and regulations is all it would take. In the meantime, lets go after REASONABLE fees until the regulators & GSEs see the light of day.  http://mfford.com/html/c___r_fees.htm