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Comment on Financial Reform Implementation
To Whom It May Concern on this day of August 17, 2010:
As a certified residential appraiser I would request the Appraisal Foundation and Appraisal Institute be added to those invited in your deliberations as stakeholders. Appraisers are an intricate part of the appraisal equation regarding appraiser education, USPAP, customary appraisal fees, and overall compliance, to name a few.
Appraiser fees have been reduced by the AMCs (Appraisal Management Companies) partnerships with Lenders/Banks. Their contractual agreements have placed appraisers in financial ruin without any regard to the financial feasibility of producing a report. In a free market, most professionals set their own fees according to what the market will bare. AMCs have taken a portion of appraisal fees without the consent of the appraiser. The argument, appraisers accept the orders at a reduced fee, does not equate as it was a forced takeover with no recourse except to comply or close the doors.
It should be noted that if certain criteria, per AMC/Lenders, are not met (i.e. sale price, accepting low fees, 24-48 hour turn-around times ), the appraiser is penalized by AMCs with less orders. Production should not be the primary consideration of an appraisal report. The appraisal profession needs to set times, fees, and analyze the market for a credible valuation of a property. This should not be left in the hands of those AMC’s who are influenced by Lenders or in essence nothing has changed in the appraisal field.
I respectfully request Appraisers be represented and present in your deliberations as we are a large stakeholder.
Thank you for your consideration in this request.
Diana R. Proper, CRA-67
|Last Updated 9/14/2010||FinReformComments@fdic.gov|