FDIC Federal Register Citations

From: BOB BLAKEMORE [mailto:bob@sunsecuritybank.com]
Sent: Wednesday, November 19, 2008 2:51 PM
To: Comments
Subject: Revised appraisal guidlines

I have been in real estate lending for over 40 years. I have been involved before any requirements of outside appraisals or evaluation. In my opinion the more requirements as to content of the valuation the more problems that have evolved. The independence of the evaluation has absolved individual loan officers and allowed them to make substandard loans for their personnel gains. Prior to "improving the evaluation Procedure" individual loan officers were held accountable to determine the adequacy of the collateral value

Irresponsible outside appraisals are accepted as fact. If proven and a complaint made the appraiser may lose there license while the lender may lose large amounts of money. These problems were a primary contributor to the sub prime crisis.

In summary I believe that the regulation is being directed in the wrong area and cannot be solved in the area that this legislation is directed at.