Federal Deposit
Insurance Corporation

September 16, 2010

Regarding TAVMA's letter indicating that Customary and Reasonable Fees for appraisers would be harmful to AMC's is indicative of a short-sighted and downright juvenile mind set accompanied by a complete lack of understanding of the appraiser and the appraisal process. The fact that the AMC's chose an unsustainable business model and have continued that business model despite the harm it has done to appraisers and will likely harm the entire banking industry if not corrected, and then have the gumption to whine about it is incredible.

AMC's assume that appraisers can make up for reduced fees in volume. The fact is that prior to HVCC most experienced appraisers were working at capacity. Lower fees for AMC work was seen largely as fill work for the inevitable slow periods and a way for inexperienced appraisers to get a foothold in the industry. The idea that an experienced appraiser can take on infinitely more work to make up for increasingly lower fees reduces appraisers to robots with the ability to work without sleep or any enjoyment of life, but the AMC's appear comfortable with that notion. I am sure more than a few appraisers are not only teetering on the edge of financial ruin, but complete exhaustion - not due to a lack of work, but due to artificially low fees.

Perhaps, if the AMC's have to deal with the results of their poor business decisions and, in some cases, unbridled greed for as long as appraisers have had to deal with it, they will make wiser decisions in the future.

Elaine S Farrington Johnson
ESFarrington Appraisals Ltd