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Comment

Our industry has been through a number of changes that have been designed to streamline the appraisal process. The further the industry gets away from the use of the licensed appraiser, the more the process is weakened. Using unlicensed and/or untrained individuals for the inspection process is a mistake. The inspection process of the appraisal is important and this provides the appraiser the foundation for the appraisal report. The appraiser must put his/her eyes on the subject property. Even the use of exterior only appraisals should be limited. AVM's are only as good as the information inputted into the system and that information will age as less appraisers are involved in the process. Appraisal waivers will prove to be a disaster. Please remember the crash of 2007? We are headed that direction with the "improvements" to the appraisal process. My suggestion is please stop trying to "improve" the appraisal process by removing the one facet of the appraisal process which is crucial to valuation--the licensed and/or certified appraiser. If you want to actually improve the process for expediency, start with form redesign. For example, dispense with the MC Addendum. This form is onerous and ridiculous in its design. Or stop with the requirement for completion of the cost approach except with new construction. Dispense with the PUD section beneath the income section. Stop with requirement for appraiser photos of the comparable sales; photos from MLS should be sufficient, especially in rural areas. Not only is this time consuming, but it is also dangerous for the appraiser in some areas. In addition, removal of the AMC component of the process would also be helpful. This layer in the appraisal process suppresses appraiser fees and inserts a management level which is simply not necessary. Communication directly between the lender/underwriter and the appraiser is important to increase timeliness of the process. These are just some suggestions I have for streamlining the appraisal process.