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Comment on Financial Reform Implementation


August 18, 2010

Please do not rely on fees that are charged by AMCs as an indicator of reasonable and customary. These fees are well below the normal fees that were reasonable and customary prior to the implementation of the HVCC. Most appraisers that I know and including myself, were strong armed into accepting less than normal fees under the very real threat of losing so much business that my business would be faced with bankruptcy. I am a part of a very large appraisal family that have independent offices in northern Minnesota, Scottsdale Arizona and the Seattle Washington area. We all agree that the attached survey conducted by a la mode is an accurate depiction of appraisal fees for our respective areas.

Thank You,

Larry A. Bennett, SRA
The Appraisal Office, LLC




Last Updated 9/14/2010 FinReformComments@fdic.gov