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Comment on Financial Reform Implementation

August 20, 2010

This is what AMC's are now asking of appraiser's ..so they can get around the usual and customary rate problem...

By accepting this assignment, you are hereby stating that you are being compensated at a reasonable and customary rate as per the Dodd Frank Act ( HR4173) and/or Mortgagee Letter 2009-28. If you disagree, then do not accept the assignment. Our extensive research in your area indicates that this is a reasonable and customary rate. If you disagree, please decline the appraisal and indicate that the decline is due to compensation.

the fee was half what a normal or customary "pre AMC" fee would be!!
you have to establish minimum national fees for different reports
from the basic URAR to complex
it's not that hard or complicated
please remember AMC's are bleeding everyone not just the appraiser they are very similar to an organized crime tax or "protection fee"

Michael Riley

Last Updated 9/14/2010 FinReformComments@fdic.gov

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