GSE Waiver & Data Collection Data

[Mejappz]

While it is true that appraisers rely on multiple third-party sources, not all sources are equal in significance or legal status. Data that serves as a substitute for personal observation—particularly property inspection data collected by someone else—invokes higher legal and professional obligations. In Florida, that data must be collected under supervision if it forms the basis of an appraisal report. Comparisons to passive data sources like MLS and tax records are not valid under either USPAP or Florida statute. The appraiser is not just responsible for truth, but for reasonableness, credibility, and lawful supervision of the valuation process.

If you don’t like that, lobby the Florida Legislature—but Fannie Mae policy does not override state law. Despite what some unethical stakeholders imply, secondary market participants like Fannie Mae are not above state regulation. Appraisers are licensed by the state, regulated by the state, and accountable to state law. The fact that a GSE permits an appraisal practice does not make it legal in Florida—or in any other jurisdiction where statutory supervision is required

 

[djd09]

USPAP has a definition of inspection...and so do State laws

 

[Justinjla]

The issue in Florida is not whether USPAP requires a personal inspection—it does not—but whether a licensed or certified appraiser can credibly and legally rely on property data collected by a third party whom they neither hired nor supervised. Under Florida Statute § 475.612, any work used as the basis for an appraisal report must be supervised and approved by the appraiser who signs the report and assumes full responsibility. If the appraiser has no oversight of the property data collector—particularly when hired by an AMC—there is no legal or professional basis to claim supervision. This arrangement may violate Florida law and expose the appraiser to disciplinary action. While Freddie Mac and Fannie Mae may permit such practices under certain conditions, those investor guidelines do not override Florida’s licensure statutes or the appraiser’s obligations under USPAP. In Florida, accepting third-party data without meaningful supervision creates legal, ethical, and professional risk.

Do appraisers in Florida rely on any 3rd party data sources that they do not have direct supervision over?

 

[Mejappz]

Do appraisers in Florida rely on any 3rd party data sources that they do not have direct supervision over?

Yes, appraisers use unsupervised third-party data all the time—but not as a substitute for direct property observation. The distinction lies in what the data is used for, how it’s obtained, and what laws govern its use. The “we use MLS too” argument conflates fundamentally different categories of information, and in Florida, that conflation could put a license at risk.

 

[glenn walker]

Yes, appraisers use unsupervised third-party data all the time—but not as a substitute for direct property observation. The distinction lies in what the data is used for, how it’s obtained, and what laws govern its use. The “we use MLS too” argument conflates fundamentally different categories of information, and in Florida, that conflation could put a license at risk.

How ?

 

[J Grant]

Do appraisers in Florida rely on any 3rd party data sources that they do not have direct supervision over?

Not to replace our own inspection. That is unique to your PDC program
Of course, appraisers can rely on third-party data sources we do not have direct supervision over for other segments of the report. Why did you ask it? You knew the answer and we knew that you know that we know the answer.

 

[Mejappz]

I can't believe the number of appraisers in this state who are ignorant of their own state laws. Their mindset seems to be, "If Fannie Mae approves it, then I suppose we can proceed."

 

[George Hatch]

Yes, appraisers use unsupervised third-party data all the time—but not as a substitute for direct property observation. The distinction lies in what the data is used for, how it’s obtained, and what laws govern its use. The “we use MLS too” argument conflates fundamentally different categories of information, and in Florida, that conflation could put a license at risk.

"different categories of information" will be an interesting argument for appraisers to make. Especially when what is under regulation is the appraiser's own work. What they actually did. What they were actually expected to do.

"Was there an inspection in this assignment?" Somebody is going to ask this question, and somebody is going to have to answer it.

 

[chad hampton]

If they aren’t doing the appraisal inspection, why do they introduce themselves as “I’m Jim, and I’m here for your appraisal”?

In some states impersonating an appraiser is a crime. Probably why they decided to get all those state board members paid off before they rolled this **** out

 

[J Grant]

If they aren’t doing the appraisal inspection, why do they introduce themselves as “I’m Jim, and I’m here for your appraisal”?

In some states impersonating an appraiser is a crime. Probably why they decided to get all those state board members paid off before they rolled this **** out

They are not impersonating an appraiser but the whole system is set up so that the party allowing access to the property and the investors who buy the loans are not too clear about the whole thing

Data collection by a third party is NOT an inspection - USPAP draws the line of when an inspection is part of appraisal practice as when it involves judgments, opinions and analysis.