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Comment on Financial Reform Implementation


August 19, 2010

Hello

I am only one small business person who has a one person appraisal office. I am deeply concerned about what is happening to my industry, with HVCC now and the climate it has created the AMC's actually pressure appraisers more than anyone has ever pressured me, not so much on values but with super fast turn times where the job canít be done as it should be or you get kicked off the list.

Also they are not concerned with geographic competency, some are starting to think about it but look the other way, all they want to do is place the order with the cheapest and fastest appraiser and not much emphasis on quality. When I started at the start of FIRREA in 1992 I looked forward to a career as a professional, fees were about $275 for a standard report, now they are being pushed down to almost that number. Why should appraisers give up part of their fee to the AMC's, what other industry absorbs the cost increases associated with new regulations? Gas companies did not, same with other goods. I now have to work 7 days a week to make what I used to. I do understand some rules need to be in place as too many appraisers were trained to hit estimated values period, good appraisers knew when to say no. Now that appraisers have no client loyalty a lot of them are just slamming the appraisal which is making a lot of them come out too low or too high as they are not getting paid nor given the time to do proper research, an example is with two day turn time, a sale could not get into MLS that closed the day before your effective date but show up in MLS 2 days after you turn in the report. Another thing AMC's are doing, they charge their client when the appraisal is ordered and then some hold payment to the appraiser for 45 days, since we have zero recourse against them for not paying use timely or not at all, when they are using our money, if they go under we do not get paid. We need to be allowed to operate as professionals and not treated like kids, we have overhead and most of us try to do a good job. You can not legislate honesty as crooked people will stay up late to try to figure out how to beat the system. Lastly why does the FBI state mortgage fraud is up since HVCC?

I am willing to have a discussion of the issues with anyone anytime, it needs to come from appraisers in the field as most of us are one person shops.

Dave

David P. Caddell
Caddell Appraisals Inc.




Last Updated 9/14/2010 FinReformComments@fdic.gov