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Question for you on this - If this means that data from a data collector cannot be used in the appraisal, because the appraiser does not supervise the data collector, then what about all the other third party data that is commonly used in appraisals? Do you supervise and approve the folks at the tax office, whose data you use for the subject and the comps? Do you supervise and approve the agents who put data in MLS that you use for comps (and sometimes the subject)? The FEMA folks? The structural engineer whose report you used for evaluating that crack in the foundation?
If it means what you assert, how are you not already in violation?
Ah, I see you're taking the same approach Justin did on the other thread.
MLS data, FEMA maps, and similar sources absolutely support the appraisal. They’re used every day by appraisers in Florida and across the country. But here’s the distinction—
they’re supporting data, not delegated appraisal functions.
Florida Statute § 475.612 doesn’t apply to the use of public or third-party reference data. It applies specifically to work that forms the basis of the appraisal report, meaning tasks that would otherwise fall under the appraiser’s own responsibility—like inspecting the property, determining condition, and collecting physical characteristics that directly influence the value.
When an appraiser relies on a third-party property data collector to complete a physical inspection—and the appraiser didn’t hire, train, or supervise that person—
that becomes contributory appraisal work under Florida law, and it must be
supervised and approved by the signing appraiser. County records, by contrast, are not being used to
replace the appraiser’s role; they’re just part of the standard reference material appraisers have always used to cross-check or support their analysis.
Trying to blur that line is a weak argument. Reference data doesn’t trigger a statutory supervision requirement.
Delegated valuation work does. That’s the line Florida draws, and until the law says otherwise, that’s the one appraisers are bound to follow.