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Comment on Financial Reform Implementation


August 31, 2010

I was reading an article in the AppraiserNews about AMC's requiring appraisers to sign a statement, the paragraph reads as follows:

Rest assured, the AMC's will not take this lying down. They already have started coercing appraisers by making them sign a statement prior to accepting an assignment that the fee that they are being paid is "customary and reasonable". -- Gary Crabtree, SRA
Affiliated Appraisers, Bakersfield, California

COERCING IS THE CORRECT WORD HERE!! AMC's should not be allowed to make us sign such a statement... they know very well we are already forced to accept their low fees or we will not receive any work from them.

Also, I would like to suggest a solution: that AMC's not be allowed to use ANOTHER AMC to fill their client needs - this cuts our fees even more because then 2 AMC's want a cut of the appraisal fee. I believe there should only be 1 AMC between appraiser and lender to avoid paying appraisers so low fees and at least come a little closer to "customary and reasonable" fees, which will never be true anyway. But it might atleast let us stay out of the poverty level.

I think AMC's serve a good purpose: they edit our work and help reports be close to perfect, among other jobs they perform for the appraiser, so they deserve to be paid. But GREED is keeping this whole issue in mud. There could be no lending without an appraisal and if we all went on a strike, then maybe we would see some justice. Until then, I believe we will be FORCED to accept pennies for our services.

Luisa Ocasio
State-Certified Residential Appraiser
AR & ASSOCIATES, P.A.




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