Comment Detail

Comment

The proposal is falling far short of reliable checks and balances systems. One primary purpose of utilizing an AVM, is to replace the human real estate appraiser for the benefit of lenders and detriment of consumers. All AVM's are programmable and therefore able to be manipulated by a person with potentially biased interest, or at the least, controllable by a person whos errors may result in systemic data deficiency which grows with time. When a human appraiser makes a mistake, they can be held accountable. That mistake can be corrected and methods altered to prevent repeat mistake occurrences, or their licenses stripped by state boards to protect the public from reckless practices. When a human appraiser acts in a biased manner, there is an individual to be held accountable under state licensing rules and licensing boards. When an AVM may have errors, intentional or unintentional, the ramifications of those errors may have far reaching consequences, if ever discovered in the first place, and there is no personal accountability. The AVM systems are largely built upon the labor of human real estate appraisers and the data they have produced from years and decades past. The longer the period of utilizing AVM's in leu of human appraisers, the greater the risk for systemic data inadequacy and undetected program implementation error and peramiter setting error there may be in an AVM system, there is to occur. The inadequacy of the AVM systems grows with time as systemic process errors influence flawed data output into the future. Unlike when dealing with a human analyst, whom constantly runs through redundant logic checks which account for the diverse possibilities of human motivations, which a human often can interpret well, an AI system and automated system will never successfully recreate. Because an AI and/or an AVM system is merely a robot and not a human being. Stop attempting to work us out of long term career positions in favor of automation, the effort is self defeating and is not transparent. The shift to using an AVM instead of a human real estate appraiser brings plentiful opportunities for predatory interests to game the lending systems silently in the back ground and completely take advantage of unsuspecting consumers. The AVM utilities will never be as good as a human real estate appraiser, because the AVM system is only as reliable as the human programmers. When the lending industry moves to using an AVM system, they are essentially substituting tens of thousands of licensed professional appraisers for a small set of unaccountable technical programmers. The idea an avm system can be audited by an appraiser for reliability is preposterous, because as all home sales, refinance efforts, and assessment efforts become automated, the appraiser will be as powerless as anyone else to correct systemic data mis interpretations and imbalanced data results, because the AVM systems will drive the entire market. This is too tempting for predatory interests to resist, they will manipulate the data outputs for their own gain. To substitute the human appraiser for an AVM utility is synonymous with abandoning the merits of checks and balances systems, there will no longer be any check to power and whomever programs the AVM systems will dominate all lending and housing markets. We could write volumes on how short sighted the lending industries moves to AVM systems may be. In fact, we have already done so and written volumes on this exact subject matter at www.appraisersblogs.com, which I encourage you to read. The author Jeremy Bagott mentions these industry shifts in many of his articles, which I encourage you to read as well. Exploiting gutted US mortgage underwriting. Indeed.