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Comment on Financial Reform Implementation


August 17, 2010

Dear FDIC,

I read that the "customary and reasonable" fees paid to the appraiser, dilemma, will be figured out by having us fill in a drop down box with what we are "now" being paid. What we are "now" being paid is NOT customary and reasonable. I am afraid that what we are now being paid will become the new customary and reasonable. This is quite unfair and very transparent. The guest list to the summit is truly telling in itself. I hope that you will take into consideration those of us actually in the profession even though none of us have been invited by the Obama Administration to participate in the fate of our profession. What you need to do to figure out what is "customary and reasonable" is find out what we were being paid "before" the implementation of the HVCC. HVCC has been a hindrance more than a help. Too many people running AMC's do not know enough about this industry and what is worse, most are National, and do not concentrate or provide good service to anyone. The HVCC was implemented to put blame on appraisers for the downfall of the housing market. There are bad apples in every field, but you do not treat everyone in the field like they are bad and change the way business is done. Appraisers report value, we do not make it.

FYI, our fees have not changed in decades. When I started 10 years ago, we were receiving $350 for a full appraisal. That number did not change until HVCC, and it went DOWN to $200-$249. Our pay went down 30%!!!!! Has anyone in the government then a 30% paycut??

Sincerely,
Casey




Last Updated 12/7/2011 FinReformComments@fdic.gov