Comment on Financial Reform Implementation
October 12, 2010
I am writing to you today regarding the proposed regulations under the Financial Reform Bill for appraisers. I have been an appraiser for 15 years. For 5 years I have run my own company. For most of those years, I have been able to make a decent living while educating myself and adapting to all the changes to the appraisal industry. The institution of HVCC has decimated my business and almost brought me to financial ruin. I agree, of course, that undue influence on appraisers is not a good thing. A better way must be found though. I have been forced to work for AMC's, at ridiculous fees. In no other industry does an management company take 75% of the fee for doing nothing, while the appraiser who is educated, licensed, legally responsible and doing all the work receives 25% of the fee. In my experience, the worst part has been that these AMC's, who get paid up front for the appraisals do not pay the appraisers. This is unconscionable. I am reduced to received 25% of the fee and now have to pay an attorney or collection agency to collect those fees for me. Please, please, find a better solution. I have done my due diligence by becoming an expert in my field. Please do not let my 15 years go for naught.