Is that not Significant Assistance?
Is the property inspection by an unlicensed person considered assistance?
We came across an article written by fellow appraiser, George Dell. Some of you may have heard of him, read his blog, or taken one of his classes. This article “What is a Hybrid?” hits home to many of us and thought it was worthy of sharing.
Those promoting hybrid appraisals have been claiming USPAP compliance. Well anyone who has ever taken a USPAP class knows no form or product is USPAP compliant. The appraiser’s actions are what make a report USPAP compliant. In George’s article he points out the discrepancies within USPAP when completing these products and asks a lot of good questions. VaCAP encourages all appraisers to read his article. Even if you have no intentions of completing a hybrid appraisal, there is some good information he shares.
A few weeks ago VaCAP raised a question concerning § 54.1-2011 Necessity for License. This Statute states any unlicensed assistance must be directly supervised by the licensed appraiser. That begs the question, is the property inspection by an unlicensed person considered assistance?
USPAP FAQ 255 states Contributions made by appraisers that constitute significant real property appraisal assistance include identification of comparable properties and data, inspection of the subject and comparables, estimating, etc.
Well what about the assistance of the non licensed person, the property inspector? Is that not significant assistance? If that is considered assistance, (and common sense tells us it is) Virginia law requires them to be directly supervised by the licensed appraiser.
And here is another little wrench that needs some attention. A few days ago VaCAP received an email from a member informing us an amc contacted him about completing a hybrid appraisal and the HOMEOWNER WAS PROVIDING THE PHOTOS! Why not just let the homeowner determine the value?
Now we want to ask for your assistance. Because hybrid appraisals are being pushed by AMC’s and lenders and there is more than one concern about these products. We are asking each of you to attend the VREAB meeting on Tuesday July 31 and ask the Board for guidance on these products. Let’s get this addressed up front before someone has a disciplinary case over these products.
There will be a public comment period in which everyone will have 5 minutes to speak. Please plan on attending and asking the VREAB to issue guidance these products.
Tuesday July 31, 2018
10:00 AM 2nd Floor Board Room 4
Department of Professional and Occupational Regulation
9960 Mayland Dr
Richmond, VA 23233
Thank you for supporting VaCAP!
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