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Comment on Financial Reform Implementation
August 17, 2010
Regarding appraiser independence and a simple solution to eliminate appraiser pressure.
My business volume is down approximately 75% since HVCC has been implemented. This is because my clients can no longer order appraisals from me directly. These clients have been developed and maintained for over 20 years and with a stroke of Andrew Cuomo's pen have all gone away. This was done to "protect" appraisers from the pressure to appraise a home based on a pretermined value.
Simple solution: Make it illegal to ever mention, discuss or insinuate an estimated value, loan amount or "needs" of the borrower to an appraiser. If there is no pretermined value, then there is no pressure to "hit" that value. Make a national hot line to report abuse. The only exception would be in the case of a purchase where the sales price is important market data.
In conclusion, I would ask that you please allow loan brokers and others to order appraisals directly from independent appraisers. This will keep costs down for the consumer and restore financial health to a needed group of Americans.
|Last Updated 9/14/2010||FinReformComments@fdic.gov|