Those complaints are reasons we charge appropriate fees,  keep your fees up, and happily answer all complaints

Not all states are as honest as yours was in addressing the complaint. Annoying as it was, you were still lucky.

As mentioned previously, moms is doing them so I learn a little bit about them. And I did test lookie once but never actually completed any. What gets me is they have the comps pre selected for you based on various utility tools software. Word on the street is their time estimates to complete are a minimum of 75% understated (states half hour, but 2 hour min), and also the comps are typically very aggressive and unreasonable. I’m thinking that if anyone gave alternative product approaches a serious review with the intention of submitting to regulatory authorities it would be easy to prove the biased intention behind the structure of engagement. Just guessing because I won’t engage. The system runs mirrored to what we know, a system of backwards rewards where if you don’t take the time to be ethical and detailed you naturally get higher income than those whom are complying with the proper spirit of ethics. People often position and argue it’s in the book. What people are missing is the spirit of ethic, the spirit of law as intended. The spirit of consumer protection is obviously being circumvented with quickie products and avm use. Then again on the other side, they’re likely jr liens and such so there is some fair balance. But wait, if this process gains wide spread credibility will the engagement still be limited to jr liens? Doubtful.

Sure it’s reliable, absolutely. Unlicensed home inspectors are reliable right? I mean those fly by night high turnover insurance inspector position guys certainly have strong working history in real property inspection and physical state analysis. Last time I shopped for a competent highly skilled inspector for just one single utility system review, the cost was minimum 100 dollars. I’m up for avm’s, and I only need 550 for them, so I can recreate appropriate process as is already well established with the 1004 form approach.

Excellent post Xpert

If the forms are really USPAP compliant, why don’t they say:

Extraordinary Assumption One: “Identified [delete and verified] subject characteristics from an ASSUMED reliable data source ”

Or more broadly identify the ‘valuation guesstimate’ as a made up value definition that has nothing to do with market value and in which we employed a hypothetical condition that all the steaming pony loaf (ok, so call it hybrid data if you prefer) was credible and any adjustments made supported.

The lenders do not WANT to be honest, and more egregious is that neither federal, nor state regulators have the integrity to stand up and say these types of reports are inherently misleading. Small print giving the appraiser ‘permission’ to add such research and data as they feel is necessary (for the original chump change fee) does not adequately protect the public and United States.

This should not be a serious consideration right now. ONE GLANCE at the forms proposed; and ‘leveraged big data’ (I still contend steaming pony loaf is a more accurate description) is enough to say (1) these by themselves don’t come close to USPAP compliance; and (2) they will promote non compliance and facilitate fraud.

ASC and other feds stopped PACE PRO as it was originally proposed why are they so silent now?

Per USPAP:

“When a signing appraiser(s) has relied on work done by appraisers and others who do not sign the certification, the signing appraiser is responsible for the decision to rely on their work. The  signing  appraiser(s)  is  required  to  have  a  reasonable  basis  for  believing  that  those individuals performing the work are competent. The signing appraiser(s) also must have no reason to doubt that the work of those individuals is credible.”

“have a reasonable basis for believing that those individuals performing the work are competent”

I would like to hear from appraisers doing hybrid appraisals. Are you vetting these 3rd party “inspectors” or simply relying on amcs for selecting the fastest and cheapest “inspectors”?

The complaint went nowhere but you still have to go through an annoying process at the state level.

My 2 cents.