Federal Deposit
Insurance Corporation

From: Dan Tosh
Sent: Tuesday, April 01, 2008 11:44 AM
To: Comments
Subject: Agency Information Collection Activities: Comment Request - 3064-0082, 3064-0083,

THE SOLVE:

Even though the Feds have lowered the interest rates, it doesn't matter unless they pass the "lower rates" on to the consumer. The banks get to borrow from the feds at a lower rate, use that money instead of their own and then tell the homeowner, would you like to lower your payment? OK Here's our new rate, Oh, wait a minute, the house won't appraise, sorry, Have a Nice Day!!!!  We need to force the lenders to do a "rate and term" reduction of an existing loan without having to re-qualify the home with a new evaluation. This will save more than 50% of the homes in foreclosure.

If an appraiser is either not qualified or comments fraud, remove or censure their license. We have licenses and a license is a privilege not a right. We keep trying to re-invent the wheel, so that one or two "gatekeepers" can control everything and be the king. With this kind of responsibility comes great power and ultimately corruption. I believe that lenders, homeowners, friends and family of homeowners and every other interested party should have nothing to say to the appraiser about the undesirable results. Let us do our job as we've been trained to do and if we need punishment, let the regulators do it. I'm sick and tired of everybody shooting the messenger. Appraisers REPORT history and analyze the facts to form an opinion. We have no power to create anything. If the defined "market" value is the appraisal problem, then the assigned value should be supported by the "market".

If it were truly a crime to bribe or threaten an appraiser, things would start to improve. It is a crime to bribe or threaten a police officer and though there are bad police officers, for the most part the system works, because the folks involved in such activities are dealt with severely. Perhaps appraisers should be sworn in as federal officers.

These are just my thoughts, but what do I know I only have 35 years experience

Dan J. Tosh, PhD, JD