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Comment on Financial Reform Implementation


August 18, 2010

First, let me thank you for all the work put in to the reforms packages completed this summer. These reforms will go a long way in improving the quality of certified appraisers lives, financial health and ultimately, the quality of individual valuation reporting going forward.

Along these lines I would like to make one suggestion; currently the practice of "broadcasting" out to 20,30, or more appraisers in a 100 mile radius, or more, a valuation assignment ordered through a appraisal management company. These orders typically, are for a significantly reduced fee, and have very quick window to complete the report. The very first appraiser to accept this order, under these conditions, gets the assignment. Neither quality or geographic competency are taken into account or price and speed. This does not represent thoughtful selection of an appraiser or any type of concern for quality. This practice should be outlawed and illegal. Given that during the "boom" years this was the business model for Countrywide and their owned Appraisal Management Company; Landsafe, I think is a fair example of this practice can be extremely dangerous. Please consider in your rulemaking period the banning of "mass broadcasting" of valuation assignments.

Again, thanks so much for all your efforts as we continue to try and improve the quality and safety of individual valuations and help to maintain and protect the public trust.

Tim

Timothy K Goessman
State-Cert. Res. Appr.




Last Updated 12/7/2011 FinReformComments@fdic.gov