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Comment on Financial Reform Implementation


August 17, 2010

Please do not let big corporations buy their solution to appraiser fees.

The AMC model is a leech on the appraisal industry they provide no value to the appraiser while they take a high percentage of our fees. The AMC model may or may not be a benefit for the lending industry if it is than they should pay the AMC's fees.

The HVCC thrust the AMC's into the industry my personal experience with them has been mixed

First American/E-appraise It (the reason for the original lawsuit) is the biggest exploiter of appraisers and appraisal reports. I worked for them for 2 weeks before I told them to remove me from their list. It so obvious to me that in addition to paying extraordinarily low fees that they are also mining data from the reports as they are very specific on how the report is written and what uniform software is used.

C2C Appraisal Management is who I receive most of my business from now. They work for Prospect Mortgage which was my best customer before HVCC. I was able to maintain my relationship with them based on my past work. The fee splits have cost me over $20,000 in reduced fees over the time of HVCC's inception. I count myself as being lucky as a lot of appraisers I know have been put out of business, but I am also not happy about working for less.

I have my own website by A La Mode - that does everything the HVCC requires.

After I lost 75% of my customer base, small brokers, to AMC's I was unable to be added to any of the AMC's that the wholesale lenders insisted on using. I applied to over 20 different AMC's I was only added to 3 or 4 and I receive no business from them. I have lost my ability to market my company to the lending business.

Thank you for your time and consideration.

Respectfully submitted,

David Denton
Denton Appraisal




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