Federal Deposit
Insurance Corporation

Tue 8/31/2010

To whom will listen,

I have been appraising for 32 years and for the last 1.5 years since HVCC has been set up, the industry has suffered greatly with the establishment of AMC's.

On a daily basis I get inquires for fee and turn around times. I get less than 20% of my quotes as the key for management companies to obtain the rock bottom appraiser. Most fees offered by management companies are near break even as far as business costs and the larger percentage offer fees below the cost of operation. It makes no sense to work for these companies which now employ appraisers with minimal experience and in many cases using people with no license in an effort to not have to pay for additional help in completing assignments.

The developer of this law never took into consideration that we are in times where the most experienced appraisers are needed and the ones with minimal experience in the industry. This change has hurt the industry terribly. The public has to pay for two and many times three appraisers because the quality or reporting is so poor. This has now become a bonus to the AMC's because the first appraiser sent out to do a $200+- job with little experience needs to be reviewed. Many times a second appraiser is sent and again is not familiar with appraisal process and that can trigger a review appraiser. So now the public can be charged two to three fees and it takes a long time to get through the process to refinance.

Sales of real estate is another major problem with the new HVCC and the use of AMC's. The appraisers with nominal experience are willing to travel long distances into areas in which they have no real understanding of the market. They end up doing a bad appraisal and kills the deal on a sale which continues to slow down the housing recovery. On a daily basis I talk to real estate agents who have war stories about the new bred of appraisers that you developed. They hate the system not because of the effort to get honest appraisers but the development of AMC’s who do not know what they are doing. They process the paper work and do not have people on staff that understand the real estate appraisal process.

With the AMC's in which I work for it is nearly impossible to find someone that can help out in a complex appraisal assignment. They have reviewers that do not have enough experience in real life that demand data that is not available or makes any differences in the final conclusion. My experience with review appraiser associated with AMC's is terrible. I wonder where they are getting these people as they truly do not have any practical experience and should not be reviewers.

Lenders in general do not like the AMC's, real estate agents also do not like the process as it is much less professional at this time, experienced appraiser had enough of this. It's time to help get the profession back to professionals. You must develop a way to allow the good appraisers to obtain a reasonable fee. I know that is what the financial reform is all about but everyone is asking who is establishing the reasonable fee. If you use AMC's discounted fees that continues to drive appraisers out of the market, how can that be a reasonable fee.

Strong requirements need to be made that AMC's hire a large portion of the staff that understand appraisal work and the process. Bank of America owns its own AMC and uses a heavy fee discounting system. I don't think this is fair and they are not well received in the market place.

I have used all my retirement, savings, and other methods of cash to hang on for 1.5 years while this has been tested. While you have driven out a few of the bad appraisers I have also seen the good ones leave the industry as they cannot hang on any longer. I am a member of the Appraisal Institute and have an SRA designation which implies a lot of work was done on my behalf to be a professional. I am asking for support in this matter and the sooner the better. Not only for me, but the lending industry, real estate industry, and most of the general public which you have really let down with this new process and reform.

Thank you,

Robert L. Martin, SRA