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Comment on Financial Reform Implementation


October 11, 2010

I have been an appraiser for almost 10 years. When I first heard of the HVCC, I thought to myself that this was ridiculous and it would never actually happen. How can they break down the communication process with the lenders. All the clients that I had gained over the years and formed professional relationships with, POOF! They are gone. Now, over a year later, I have had to move out of my modest home and find something less expensive with a roommate.

I know that we all have horror stories of AMC's. The unlicensed, unregulated criminals that are legally stealing our money. With the new 1004MC form, the listings that most of them want to put in the report. This was unheard of when I started in this profession. It takes me about another 3 hours to complete an appraisal than it did 2 years ago. So, I work about 25% longer on an appraisal and receive about 40% less money. Although the AMC's collect OUR MONEY up front. They will wait 60 days or longer to pay us. Many times that is after repeated phone calls asking when I am going to be paid. Hopefully it will be here before my power is shut off.. again....I make less money now then I did when I was a "trainee" at the turn of the century. I know you all would agree that the cost of living has dramatically increased since then.

The solution has to do with separating our fees, the AMC's and the appraisers. The appraiser's should be able to quote their fee and collect it at the door. The AMC's can get their fee from the lender. AMC's do ZERO preliminary research on the properties. It is not uncommon for me to get an order for $250 for a million dollar waterfront property. The fee should be at least $450 - $500, that is what the AMC's are collecting. The letter from TAVMA is completely ridiculous, they don't know what a customary and reasonable fee is for an appraisal. That is because they are NOT appraisers.

Please put an end to the HVCC now. Let us communicate with the lenders. Stop the AMC's from collecting OUR fees! We, the appraiser's, quote our fees by the time involved and the difficulty of the assignment.

Sincerely,

Brian A. Choron
Abacus Appraisal, Inc.


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