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Comment on Financial Reform Implementation


August 18, 2010

Hello

I have been an appraiser for over 18 yrs and have built a business from the ground up with my sister who is also an appraiser in the business for over 25 years. We never made "big money." But, we worked hard to build a client base of reputable lenders who never asked up to do anything unlawful (not that we ever would have) and we made a living - working well over 40 hrs a week - always.

After the implementation of HVCC we lost clients who wanted to work with us because our knowledge, integrity and work ethic made them feel more comfortable with lending on properties and trusting our appraisals.

Our income has been reduced drastically and we have been trying to stay afloat. Wr are now working for AMC's exclusively and our fees have gone down and the workload and requirements for each appraisal has increased drastically which causes us to not be able to complete the number of appraisals that we used to and we are not getting the volume of work because of the way these are assigned.

Therefore, all of the work, ethical standards, integrity of our appraisals & continuing education over the past two decades has become meaningless because being good and ethical no longer matters because we are just "in a pool" with maybe less knowledgeable appraisers who don't do as much "due diligence" and we get worked based on the same parameters as they do.

How about punishing lenders and appraisers for wrong doing and not punishing everyone in the industry - ahead of time? Our justice system seems to work that way - we don't punish law abiding citizens based on past criminal behavior of a few, why punish appraisers and make it nearly impossible for them to make a decent living? Mind you, it was an AMC involved in the problem that caused HVCC to come about.

Small business are the backbone of our economy and the American Way. Myr small business is suffering greatly. Our only other employee was a part-time secretary who we had to let go because we could no longer afford her.

We need reasonable fees and most important need to have our business reflect our performance - meaning our reputation as good appraisers should allow us to seek and maintain business directly from clients (lenders). What other service in the country does not allow a customer to order a product or service from someone that they have had past experience with and are pleased with the product?

We are already in an industry where the average age of appraisers is in the 60's. If It is nearly impossible to stay afloat with 20 yrs of experience, what young person is going to be able to make it or even attempt to under these conditions? What's going to happen in 10 yrs when there are less and less Certified Appraisers?

I am 100% for integrity in the industry. Are we going to allow the behavior of a handful of "bad apples" kill an industry that is so vital to the American Economy? Not to mention how unfair this has been to consumers who are paying more and getting less than good appraisals. Isn't the backbone of our capitalistic system that those who work hard and do the right thing get the business and success? Isn't that free enterprise?

Please allow appraisers to do there job and be able to have "arms length," relationships with lenders that they build a solid reputations with. In my opinion, the AMC's have been a detriment all the way around. However, they should absolutely be a part of the process as they were before HVCC. They should be allowed to compete with independent appraisers for clients and the lender chooses to give their business to the best and most knowledgeable. What about the fact that many AMC's have "sister" relationships with big lenders? Every big lender that I'm aware of has an AMC that it is connected to in some way. How is this making things more transparent than working with an independent appraiser?

Please consider this and let us good, hard-working, honest appraisers get back to work.

Thank you.

Sincerely,

Terri Brady
Certified Residential Real Estate Appraiser




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