I have a very simple, unambiguous perspective. Data collection should only be done by licensed appraisers. The cost would still be less than an appraisal, it would support the appraiser trainee model, and the lender would still get the benefits of the waiver, without having to send an unlicensed person into their customers home.
You have a very convoluted perspective. You want to grow the program and you are also selling cost as the primary benefit. You aren’t calculating reputational costs the costs of outsourcing data collection to vendors the lender hasn’t vetted. Meanwhile you simultaneously encourage appraisers to do data collection, but it’s hollow because it conflicts with your entire agenda.
What am I wrong about?