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Comment on Financial Reform Implementation


August 17, 2010

My name is Brian Frank I have been a appraiser for over 15 years and I have owned my appraisal company for 10 years..

I am very sadden by the recent changes in the industry for one the inability of myself to train new people , I have many clients that will not allow me to use associate appraiser or if they do I have to inspect the property with them.. This is EXTREAMLY time consuming and I know it is leading to a shortage of appraisers due to the fact the associate appraiser can not get work .

My other concern is the fee's, I believe a fair fee for the appraisal is $275-$300 for a 1004/1073. I can not believe what the expectations of these clients are , they continue to want additional information(1004mc form, google pictures, more data-comparables , listings) also they want the report yesterday with no errors but the fee keeps decreasing. I have one client that wants to pay me $187 dollars for a 1004 and can not understand why I am declining the orders.

I also have a problem getting my entire company approved from vendors, they will not accept me as a company and they want the order completed by the appraiser on the order sheet but depending on the day and time that appraiser may not be able to do the order so what are we left to do but decline the order.

I hope this information helps in the decision making process, I love what I do but it is a daily fight to keep going .

Brian Frank




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