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My name is Michael Simmons. I am a founding principal and Co-President of AXIS Appraisal Management Solutions, a national appraisal management company. I have been privileged to spend 45 years in the real estate, lending, and appraisal industries. My father was an appraiser - and I have the deepest respect, admiration and affection for appraisers and the role they play in the world.

I appreciate that FHFA has seen fit to invite so many stakeholders to weigh in. I have participated, along with others in our firm, in helping to formulate responses from both the Collateral Risk Network and REVAA – and both organizations have added thoughtful, constructive, and valuable ideas and data to your investigation. You have much to digest and I don’t need or want to re-visit those positions.

I do wish to add my own individual perspective about why our path forward’s success hinges on one small, but importantly, distinct approach. We must capture the appraiser’s full and willing participation.

Appraisers are analogous to the root system of a tree; in this case the ‘tree’ is Collateral. Appraisers supply the nutrients that feed the growth and health of the entire organism, from the trunk to the branches to the leaves and to the fruit that keeps the system functioning. This flow of information operates as a continuum and this process is a requirement in order to maintain the health of the system.

The illustration above is designed to point out that we risk approaching the solution backwards. We need to engage the appraiser profession across the spectrum of their opportunities. Rather than employing 3rd party property data collectors (PDC’s) for hybrid appraisals or perhaps in conjunction with an AVM or some other combination of collateral options, we should be focusing on applying this piece of ‘inspection modernization’ for use by all appraisers beginning with full appraisals and then extending to all other assignment types.

Support and teach appraisers that the growing tech stack and outsourced inspections are tools that will enhance their efficiency and proficiency and they’ll discover enhanced productivity. The result will be an ability to increase their per hour earnings and a willingness to embrace multiple appraisal products once they accept the value of mechanizing inspections. And … the industry will become more attractive to new entrants. Attraction, not promotion is the key. Here are some of the steps involved:

- Have the GSE’s finish establishing a set of standards for inspecting a property. They were almost there at one point with their Pilot Program.
- Establish training standards for PDC’s that include testing protocols. Imperative for lenders, regulators, investors and (especially) appraisers to trust the process.
- Establish licensing requirements.
- Appraisal Trainees should have inspecting be the first level of their appraisal training (the better to monetize their value for their employing supervising appraiser). Perhaps PAREA can be modified to address just this element in a trainee’s instruction schedule.
- Real Estate Agents may have licenses but need specific, standardized training and testing.
- ANSI Home Inspectors, HUD REACH Inspectors, ICC Inspectors – are all licensed experts in inspecting so they likely need only document that experience by passing the same standardized test.
- If appraiser’s are able to utilize new technology, deeper data sets, and trained PDC’s while fulfilling full origination appraisals for all clients, they will adopt it as their fundamental system of addressing all assignment types.
- This also fits with the GSE’s pending model of obtaining one strong set of PDC data and structuring the resultant report based on the required scope of work for each assignment.
- This will have the knock-on effect of encouraging many of the best appraisers to engage trainees because they can monetize that trainee in short order by training them first to inspect and then use the opportunity to grow their appraisal business. This is important as the world becomes more complex. Appraisers benefit from scale as well.
- Many professions have mastered the art of developing support positions to mechanize specific functions. The Appraisal profession is overdue.

The issue is not faster and cheaper; the quest is to improve efficiency, expand availability, and improve productivity all while elevating the quality of appraisals throughout the spectrum of appraising.

If you’ll pardon the homily, ‘To build from the bottom up, one must teach and train from the top down’.

With respect,
Michael SImmons