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Comment on Financial Reform Implementation

November 7, 2010

I appreciate the your taking the time to heed the cries of the people that these rules and regulations are affecting. Many times, regulators ignore the guidance of those with boots on the ground experience.

This message pertains to "Customary and Reasonable Fees". This was a nice attempt towards appraiser independence. Unfortunately, the appraisal management companies and those who will only pay minimal fees always find a loophole in the wording. 

The large AMC's now claim they are "unable" to determine C&R fees in the local marketplace yet they EASILY charge the consumers $400 for a 1004 URAR and pay the appraiser $175.   They have stolen over half of our fees now for TOO LONG.  We need help as the small guy simply cannot fight bloated mega banks and their OWNED appraisal management companies.

We BEG of you to SLAM SHUT any loopholes that exist in the C&R wording.  The AMC's DO NOT PLAY FAIR...they do NOT care about the consumers...only about taking as much of the appraisal fee as they can..period.

The AMC's provide NO SERVICE other than order transmittal and delivery.  For this they get compensated over half of our fee.  

Please listen to the words of the other appraisal professionals and organizations regarding these issues.  They are TELLING YOU THE TRUTH.

The mega bank lobbyists that are crying that they dont know how to determine C&R fees are lying.  Tell them to check the HUD-1 statement where the FULL APPRAISAL fee is recorded yet only 40% of that fee is paid to the ACTUAL APPRAISER.

Please help save what is now seeming to be a dying profession.

Thank you

Drew Carmell 

State certified residential appraiser, Maryland CPA, MBA, M.S Accounting and B.A in finance. 




Last Updated 11/19/2010 FinReformComments@fdic.gov

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