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Comment on Financial Reform Implementation

August 31, 2010

To Whom It May Concern:

I am writing this email with regard to the reasonable and customary fees to appraisers in my area.

Prior to the implementation of HVCC, the reasonable and customary fees paid for a standard residential appraisal were between $350 and $400 per report. Variations were, of course, seen for recertification of value, land appraisals, manufactured residences, FHA, and the 2055 drive-by. For some time, in order to voluntarily do my part to help the economy, I waived my additional $25-50 for FHA additional data. The customary fee for an FHA is $375 to $425. Manufactured homes always were higher due to the additional data at about $50 plus the standard fee. Land appraisals ranged from $200-$250, recertifications at $150, and field reviews were about $200/higher for rural areas. High value homes range from $500 to $750, depending on the complexity.

The price of gas has significantly affected those of us in certain professions also - appraisals, insurance inspections, home inspections and similar. Many of the rural areas I service (such as Elbert County) do not have any public transportation and it is unrealistic to attempt an appraisal by bus even in the city.

We have all been hit by difficult economic times, but the fees paid by the AMCs are totally unrealistic. I work for a few that pay $325, but most pay $300 or less, even for high value homes or manufactured. While I don't mind sharing about $25-$50 for their "wages", completing a full 1004 for $200 to $250 when they are charging the homeowners $500 to $600 for a standard residential, is ridiculous. The homeowners are actually paying more for the appraisal than what we would charge at full fees. I have had homeowners complain about the fees, and I really don't know what to say to them. High value customers are being charged much higher fees also (about $1,000 or more).

I don't mind working for AMCs as long as they are reasonable with their fee structure. I recently completed a high value property for $225 (as a single parent my choices are limited). In the end, I would have made more per hour at McDonalds. Unfortunately, many persons are overlooking the fact that we also pay for continuing education, E and O insurance, MLS memberships, appraisal software, gas and office supplies/equipment, and our license fees.

These factors must be taken into consideration. What professional is paid $10-$15/hour? Non-professional workers often have higher wages than we do, yet are not required to be licensed, or take continuing education. There are also seminars and other educational expenses for those of us who want to keep up on the real estate industry. Let's not forget the other memberships that many of us have stopped such as The Appraisal Instutute, National Association of Appraisers, etc., that we should participate in and don't because we cannot afford the additional $400+ per year. Some of the AMCs are even charging us up to $150 to be put on their "list", from whom we never receive work. Let's not forget the usual and customary marketing costs.

We need reasonable and customary fees to reflect the above, or more of us will end up leaving the profession. My yearly income minus expenses is very close to the national poverty level, yet I am expected to be a professional. I've not had health insurance for some time - I cannot afford it.

Please take the time to examine what should be reasonable and customary fees without inclusion of AMC fees.

Thank you,

Claire B
Certified Residential Appraiser/Colorado

Last Updated 12/7/2011

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