- Joined
- Apr 4, 2007
- Professional Status
- Certified Residential Appraiser
- State
- Tennessee
There is nothing "razor thin" about the legality. USPAP and state laws have always allowed appraisals without inspections. I did a no-inspection appraisal for a big legal case over 20 years ago. For my whole career it has been acceptable to perform appraisals without a personal inspection of the subject.?? What does one thing have to do with another? There was a minimal problem of appraisers being dishonest who marked did inspect with a trainee who did not inspect. And the number of appraisers using trainees plummeted post-HVCC. If an appraiser used a runner and did not check the box of did not inspect they could be sanctioned for it.
Moving past that distraction, this is a massive influx of non-licensed non-appraisers into the field to do what used to be an inspection, now called a "data collection" to keep it on the razor-thin edge of legal. We are aware that USPAP does not require an inspection. But for the assignments where an inspection used to be done, now they are onboarding non-appraisers to do a version called PDR.
The only reason that the 1004/70 requires personal inspection is because that is the GSEs' policy when using that form. It still is the policy, when using that form.
Many are unhappy with the GSEs' decision to move away from the requirement for personal inspection by the appraiser, and they seem to want to blame the wrong entity for the data that supported that decision.
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