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Comment on Financial Reform Implementation


September 1, 2010

Dear representative Fudge,

I am a local certified real estate appraiser who is currently in business with 2 partners and we cover a 6 county region of Northeast Ohio. Our business is located in Lyndhurst, Ohio and has been serving Northeast, Ohio for over 13 years. It appears that forces outside the real estate appraisal industry are trying to put appraisers out of work. Before legislation was passed creating the use of mandatory appraisal management companies, the standard appraisal fee for a full conventional single family appraisal was between $275 and $325. Now, with lenders being forced to use appraisal management companies appraisers are also being forced to use these companies. These management companies are offering appraisal assignments for fees between $185 and $211 in most cases or to the appraiser who will accept the assignment for the lowest fee. So while the management companies are still charging the borrower over $400 per appraisal they still are only paying the appraiser only a fraction of that fee!! These management companies require 4-5 day turn around while paying almost less than half the industry standard appraisal fee. Does the lending industry really want to over work and under pay real estate appraisers by cutting there fees? I was under the impression that congress passed a bill requiring appraisal management companies to pay appraisers industry STANDARD fees in order to compensate appraisers adequately and to produce competent appraisals not sub par appraisals for the least amount of money. This is not the case with many management companies who are representing MAJOR lending intuitions (PNC Bank, Chase, Bank of America etc). According to these management companies the fees are lower but "they will give you more work" which is absurd. These companies are requiring more work, faster turn-around time and constant updates, but yet they and not paying anywhere near industry standard appraisal fees. We as a profession are not asking for an increase in appraisal fees we just want to be paid a fair amount and not have our fees cut in half!! I respectfully ask that you help me to understand how this process can be changed, who is responsible and how to correct the grave injustice which is occurring in the appraisal profession presently. I greatly appreciate your time.

Yours Truly

Lawrence Salvatore




Last Updated 9/23/2010 FinReformComments@fdic.gov