Back when we were assured that appraisers completing these hybrids would be required to be "geographically competent" I had some hope, now I see that they're going to change the meaning of that term so that a multistate licensed "valuation professional" sitting in a cubicle somewhere can complete them anywhere in the country, all hope was lost. Letting lending institutions value their own collateral is a terrible idea, and the fact that the industry is headed in this direction is an epic failure of the regulators. A "valuator" sitting in a cubicle somewhere has no "independence", they have "a boss" who expects to see the results that they want. Between that scheme and easily tweaked AVM assisted lending decisions, the fox will definitely be in charge of the hen house going forward. "Internal auditors" at these organizations will make sure all the books look good as well and no one will know how much risk is out there being offset by worthless derivatives again. An amazing amount of effort being expended towards bypassing appraisal "friction" in the lending process, which means we were doing what we were supposed to be doing.