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Comment on Financial Reform Implementation
August 17, 2010
To Whom It May Concern:
I am now a part time appraiser and have been put out of business due to the implementation of the HVCC and not being able to collect my full and due fees for my work. This is the case with many appraisers and what is mostly left in the appraisal profession is appraisers who are willing to perform less than acceptable appraisals for a lower than standard fee. There is a very very simple solution to this problem. Let us appraisers collect OUR fees for OUR work at the door. Let the AMCís collect their fees separate from ours. Appraisers have to pay database fees, E&O insurance fees, state exam fees, licensing fees and constant continuing education fees. The AMCís on average are charging $500 to the borrower for an appraisal and giving the appraiser $200 this is half of what we are accustomed to charging in order to maintain our business and on average we have to wait 60-90 days to get paid our $200 so how are we supposed to be able to maintain our profession and business not even knowing when we will be getting paid? $200 an appraisal will either put us at minimum wage earning or create sloppy quick appraisals from those who are willing to do so. That is and has been the end result. We are forced to use AMCís or we donít work. That is they way it is. Our hands are tied. The Ethics section of USPAP states our fees should be separate from management fees and any fees obtained by management companies should be noted in the report. This is to protect the consumer. Consumers should know what whey are paying for. Appraisers obtain a ton of education and money poured out into our professions so it is not so easy to let go of it. It is no different than asking a lawyer or doctor to give up their licenses. Why are the AMCís allowed to earn more money for the appraisal being ordered than the appraiser doing the work? We are licensed and responsible for our own work. An AMC is strictly there to order the appraisal that is it and the worthiness of an appraisal ordering fee is all they should be charging. AMCís are not licensed, educated, trained and until recently not even required to be registered with the state. Again, the simplest solution to this matter is let us appraisers collect our fees for our work at the door just as any other professional in the USA does. Let the AMCís collect their fees separate from the appraisal fee. They are telling the borrowers that the fee being paid is for an appraisal. They are lying to the consumers. The consumers are paying an appraisal fee and an appraisal ordering fee that has nothing to do with the appraisal and the work being done. I can not tell you how many times I have had a borrower call me because they didnít like the value then come to find out they paid $500 for the appraisal and had no ideal that $300 of that went to the AMC and not to me the appraiser. They AMCís are lying to the public. If you have any other questions or concerns please feel free to contact me. Thank you for your efforts and concern in this matter. Have a great day...
|Last Updated 9/14/2010||FinReformComments@fdic.gov|