My state (California) does not require a trainee to have a license.  I was told not long ago by BREA’s “Cynthia” (They frequently do not give out last names anymore) that BREA is even telling trainees NOT to get their licenses until they already have all their experience requirements. The reason? Because if the trainee screw up the BREA has ZERO jurisdiction over them as long as they aren’t actually signing FRT reports.

By disclosure, they can get their work credit in reports that they do not sign. While it is MY decision to decide whether a trainee (licensed or unlicensed) is qualified enough to inspect without my assistance, I am still 100% responsible for the results.

I don’t see how use of a third party stranger (broker, agent, teen kid of either; handyman or neighborhood wino) is any different…aside from the fact that I don’t get to qualify, or select them. I still have 100% responsibility.

In a BEST CASE scenario, with all the appropriate disclosures, expanded limiting conditions and use restrictions; extraordinary assumptions and a whole lot of good luck I might be ok.

Right up until someone that is not a client; wasn’t even an authorized or intended user and doesn’t like the results files a complaint with the state alleging lack of competency; that any report was misleading (due to possibly disputed value) and that the assignment conditions were too limiting to produce a credible appraisal and report. Say someone in Maryland that was a seller that accepted a revised low offer after appraisal and later wants to sue the appraiser for their loss. The complaint filing is merely to buttress their allegation in civil court.

In many ‘normal’ states this would be a minor inconvenience. You send your work file and explanation and assuming you did what your report indicates you did, you’d probably be ok. THEY would look at it in the USPAP required context of the intended use suitability.

In California, where state investigators don’t know the difference between a FNMA guideline and USPAP, or where dishonesty and outright perjury are accepted practices at BREA under its current leadership, you would be screwed. Minnesota, Maryland and Oregon are also pretty ‘iffy’.

Now, that’s a best case scenario. The fact is that every single form I’ve seen for these things tried to make them look like something that they are not. ie: a real appraisal. Want an example? How about neighborhood trends and conditions for an area you have not seen? An overly broad but essentially meaningless published study will be used to show ‘trend’ information. Doubt me? Look at current boilerplate models for narrative reports (pure fluff and filler); or any UAD form report-description could fit any neighborhood in the country (“All services within acceptable distances for the market” or similar nonsense.)

I hate to keep referring to First American’s PACE PRO product, but its one of the few that the promoter was dumb enough to post online. It was the form itself that was riddled with pre printed text reporting conditions that could not remotely have been verified by the appraiser.

There is a reason so many of the new hybrid con jobs want you to fill out reports using their proprietary online report systems; and online ‘work files’.

Its not the concept of hybrids or desk top appraisals (evaluations, or whatever other euphemisms they prefer) that is the problem.

The problem is the deliberate and intentional deception being perpetrated by their promoters. (Shortage of appraisers; cost & time benefit to consumers, Vets, ‘almost as reliable”, verified with Super-Doodle Data & leveraged with love and integrity, etc.).

If it were not for their desire to preserve the illusion of professional appraisals being performed and to foist risk on the backs of appraisers, ALL any of these hybrid promoters would need is a 3 x 5 post card ‘comp check/’appraisal’ that ONLY has the address and value on it.

Charge $100 and most of the time (50%+1) they will be within 70% of assumed market value.

I used to wonder why federal regulators tolerated these things, but after reading how big the FNMA dividend just paid to Treasury was it’s pretty clear to me. NO bureaucrat is going to suggest anything that would reduce or eliminate billions in current revenue to the feds just because it may lead to a ten fold (or worse) loss later on.

Thanks Dale.  The detailed legal argument is very interesting and Mr Harris makes important contributions to the analysis.  I’m just like what if.  What if the ‘inspector’ really is a day laborer or some ex con who can only get a driving taking photos job?  I don’t think it’s a logical parallel to mix up unlicensed people whom an appraiser may have personally qualified or approved, vs unlicensed ‘inspectors’. We all know what lengths some companies go to regarding driving appraiser sourcing costs down.  It’s fair to presume there will be even more pressure for these ancillary types of services.  Appraisal is a personal engagement where the appraiser professional takes on the position of a trusted valuation advisor, and delivers on exactly that.  If the hybrid ‘inspector’ is legitimate, why can’t we know exactly who they are and the terms of their engagement?  And why can’t I hire that person myself instead, I’d prefer to stay in control of ‘credible valuation results’ as much as possible. That’s in the book too…

After nearly two decades of owning a large shop, I sold my business and went to work in corporate America.

Today, the majority of my appraisal practice consists of doing review work.

But I also do desktop appraisals and, when doing so, the third-party inspector is always disclosed.

In fact, last month I earned $9,930 doing desktop valuations without leaving my home… dressed casually in in jeans, “t” shirts and sneakers (but I am considering getting some of those “bunny slippers”… I ‘ve been reading about lately…lol).

As a veteran Appraiser who performed his first appraisal in 1982, I am surprised that more “mature ” Appraisers don’t do desktop valuations-it’s a great way to earn a living, or do in retirement…once you know what you are doing.