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Comment on Financial Reform Implementation

August 17, 2010


I feel the following needs to be included with your new guidelines.

The use of BPO's CMA AVM should not be allowed in any part of the loan or foreclosure process. Real Estate agents have an interest in the BPO by hoping to get the listing. All of this work should be down by an appraiser and new forms to meet the lending institutions should be created if needed.

Customary and Reasonable fees should be mandatory and set to the VA Fee Schedule as the minimum paid to the Appraiser. No AMC, Bank, Mortgage Broker should set the fees.

Appraisers should be able to collect the fee from the buyer, property owner to eliminate the typical non-payment that occurs.

Since the HVCC, I have lost all my clients, my income has been reduced in half. I can not go out and market myself like the past. All Lenders should be able to accept appraisals ordered by a Mortgage Broker, Real Estate Agent Etc.

All persons involved in the transaction should be licensed and carry E&O insurance.

All AMC should be licensed in each state with a bond.

There should be a enforcement division created with a percentage of each transaction done, just like a tax.

Craig Wallace

Wallace Real Estate Services Residential & Commercial Appraisals

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

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