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	Comments on: Restraint of Trade Investigation	</title>
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		<title>
		By: Mike Ford, AGA, GAA, RAA, SCREA, Realtor®		</title>
		<link>https://appraisersblogs.com/appraisal-service-free-trade-suppression/#comment-18864</link>

		<dc:creator><![CDATA[Mike Ford, AGA, GAA, RAA, SCREA, Realtor®]]></dc:creator>
		<pubDate>Mon, 08 Jan 2018 21:08:55 +0000</pubDate>
		<guid isPermaLink="false">http://appraisersblogs.com/?p=14387#comment-18864</guid>

					<description><![CDATA[In reply to &lt;a href=&quot;https://appraisersblogs.com/appraisal-service-free-trade-suppression/#comment-18850&quot;&gt;realrose&lt;/a&gt;.

Sorry you feel that way Rose. No one of us can be all things to all people. We are who we are. Human beings with differing views. Good luck in your endeavors.

PS- *g* How can&lt;em&gt; anyone&lt;/em&gt; not agree with the political views of a republican union organizer? A fact that gives new meaning to the word schizophrenia!]]></description>
			<content:encoded><![CDATA[<p>In reply to <a target="_blank" href="https://appraisersblogs.com/appraisal-service-free-trade-suppression/#comment-18850">realrose</a>.</p>
<p>Sorry you feel that way Rose. No one of us can be all things to all people. We are who we are. Human beings with differing views. Good luck in your endeavors.</p>
<p>PS- *g* How can<em> anyone</em> not agree with the political views of a republican union organizer? A fact that gives new meaning to the word schizophrenia!</p>
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		<title>
		By: realrose		</title>
		<link>https://appraisersblogs.com/appraisal-service-free-trade-suppression/#comment-18850</link>

		<dc:creator><![CDATA[realrose]]></dc:creator>
		<pubDate>Mon, 08 Jan 2018 17:11:14 +0000</pubDate>
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					<description><![CDATA[&lt;p&gt;I agree with Retired Appraiser that we have acted to late with way too little. This is discouraging, and after nearly 40 years as a highly qualified appraiser, I am hesitant to join this union due to political views of the leader and their most vocal member named Baggins. You are losing me; we are already screwed, so I am not going to try to help residential appraisers and will, instead, concentrate on building clientele I can service rather than try to compete with low bidding residential appraisers who don&#8217;t make enough to survive. This is not to say I am not sympathetic, just disgusted with yet another black hole I would be supporting with my earnings.&lt;/p&gt;]]></description>
			<content:encoded><![CDATA[<p>I agree with Retired Appraiser that we have acted to late with way too little. This is discouraging, and after nearly 40 years as a highly qualified appraiser, I am hesitant to join this union due to political views of the leader and their most vocal member named Baggins. You are losing me; we are already screwed, so I am not going to try to help residential appraisers and will, instead, concentrate on building clientele I can service rather than try to compete with low bidding residential appraisers who don&#8217;t make enough to survive. This is not to say I am not sympathetic, just disgusted with yet another black hole I would be supporting with my earnings.</p>
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		<title>
		By: marion		</title>
		<link>https://appraisersblogs.com/appraisal-service-free-trade-suppression/#comment-16891</link>

		<dc:creator><![CDATA[marion]]></dc:creator>
		<pubDate>Sat, 17 Jun 2017 07:18:11 +0000</pubDate>
		<guid isPermaLink="false">http://appraisersblogs.com/?p=14387#comment-16891</guid>

					<description><![CDATA[And when Alexander saw the breadth of his domain, he wept for there were no more worlds left to conquer.”
-

Plutarch  c. 100 AD]]></description>
			<content:encoded><![CDATA[<p>And when Alexander saw the breadth of his domain, he wept for there were no more worlds left to conquer.”<br />
&#8211;</p>
<p>Plutarch  c. 100 AD</p>
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		<title>
		By: Mike Ford, AGA, CA AG, GAA, RAA, Realtor ®		</title>
		<link>https://appraisersblogs.com/appraisal-service-free-trade-suppression/#comment-16876</link>

		<dc:creator><![CDATA[Mike Ford, AGA, CA AG, GAA, RAA, Realtor ®]]></dc:creator>
		<pubDate>Fri, 16 Jun 2017 02:27:56 +0000</pubDate>
		<guid isPermaLink="false">http://appraisersblogs.com/?p=14387#comment-16876</guid>

					<description><![CDATA[In reply to &lt;a href=&quot;https://appraisersblogs.com/appraisal-service-free-trade-suppression/#comment-16687&quot;&gt;marion&lt;/a&gt;.

Can you elaborate a bit? Seems to me that CoreLogic is moving toward greater monopoly and control rather than toward any credible degree of &#039;fair and open competition&#039;.]]></description>
			<content:encoded><![CDATA[<p>In reply to <a target="_blank" href="https://appraisersblogs.com/appraisal-service-free-trade-suppression/#comment-16687">marion</a>.</p>
<p>Can you elaborate a bit? Seems to me that CoreLogic is moving toward greater monopoly and control rather than toward any credible degree of &#8216;fair and open competition&#8217;.</p>
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		<title>
		By: M		</title>
		<link>https://appraisersblogs.com/appraisal-service-free-trade-suppression/#comment-16868</link>

		<dc:creator><![CDATA[M]]></dc:creator>
		<pubDate>Thu, 15 Jun 2017 00:09:14 +0000</pubDate>
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					<description><![CDATA[It all gets pretty convoluted pretty quick. FTC is the Fair Trade Commission right? Fair for who? All parties, or just the ones with the best lobbyists? Where were they when the HVCC was enacted? Where were they when Dodd-Frank was enacted? While neither of these laws has language that specifically mandates unfair trade practices, they each resulted in unfair trade practices as a by-product. Maybe that was hidden from view when the HVCC went out, but not when Dodd-Frank went out. Specifically, it would be very hard to say that old-fashioned supply and demand have been in play for appraisal services in a very long time. In the wake of regulations, the bulk of appraisal users, used a small number of AMCs to handle the work load volume. That in itself is not a horrible thing, given the scope of the task and need for the organization of labor. However the ultimate affect has been a pooling of labor outside of the control of the service providers, where service providers are now competing in an atypical environment. My opinion is if you are going to regulate in a way that creates certain solutions (in this case the solution is the AMC) and that solution has a by-product of unfair or at the very least, less than free market tendencies, then the only solution to that byproduct, short of removing the original regulations, is to further regulate. This is why I support price fixing for appraisal services. The AMC model is not helping anyone but the people making money from the AMC. Isn&#039;t it just a bit ridiculous that the borrower, thinking they are paying for an appraisal, is often paying mostly for the simple task of ordering the service? Its a cash cow/added fee scam of great magnitude. TRID doesn&#039;t help either. How ironic the FTC is filing suit against the one state in the union attempting to rebalance the imbalance. Thanks FTC - great use of resources (that&#039;s sarcasm and yes, I felt I need to point that out).]]></description>
			<content:encoded><![CDATA[<p>It all gets pretty convoluted pretty quick. FTC is the Fair Trade Commission right? Fair for who? All parties, or just the ones with the best lobbyists? Where were they when the HVCC was enacted? Where were they when Dodd-Frank was enacted? While neither of these laws has language that specifically mandates unfair trade practices, they each resulted in unfair trade practices as a by-product. Maybe that was hidden from view when the HVCC went out, but not when Dodd-Frank went out. Specifically, it would be very hard to say that old-fashioned supply and demand have been in play for appraisal services in a very long time. In the wake of regulations, the bulk of appraisal users, used a small number of AMCs to handle the work load volume. That in itself is not a horrible thing, given the scope of the task and need for the organization of labor. However the ultimate affect has been a pooling of labor outside of the control of the service providers, where service providers are now competing in an atypical environment. My opinion is if you are going to regulate in a way that creates certain solutions (in this case the solution is the AMC) and that solution has a by-product of unfair or at the very least, less than free market tendencies, then the only solution to that byproduct, short of removing the original regulations, is to further regulate. This is why I support price fixing for appraisal services. The AMC model is not helping anyone but the people making money from the AMC. Isn&#8217;t it just a bit ridiculous that the borrower, thinking they are paying for an appraisal, is often paying mostly for the simple task of ordering the service? Its a cash cow/added fee scam of great magnitude. TRID doesn&#8217;t help either. How ironic the FTC is filing suit against the one state in the union attempting to rebalance the imbalance. Thanks FTC &#8211; great use of resources (that&#8217;s sarcasm and yes, I felt I need to point that out).</p>
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		By: Retired Appraiser		</title>
		<link>https://appraisersblogs.com/appraisal-service-free-trade-suppression/#comment-16857</link>

		<dc:creator><![CDATA[Retired Appraiser]]></dc:creator>
		<pubDate>Mon, 12 Jun 2017 22:03:42 +0000</pubDate>
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					<description><![CDATA[In reply to &lt;a href=&quot;https://appraisersblogs.com/appraisal-service-free-trade-suppression/#comment-16619&quot;&gt;Lee&lt;/a&gt;.

This is the best quote currently available with regard to the appraisal &quot;profession&quot;.  Although I applaud the work of Mike&#039;s group, it&#039;s too little and too late.  Appraisers have one choice:  Flee or continue to endure the abuses of slavery.]]></description>
			<content:encoded><![CDATA[<p>In reply to <a target="_blank" href="https://appraisersblogs.com/appraisal-service-free-trade-suppression/#comment-16619">Lee</a>.</p>
<p>This is the best quote currently available with regard to the appraisal &#8220;profession&#8221;.  Although I applaud the work of Mike&#8217;s group, it&#8217;s too little and too late.  Appraisers have one choice:  Flee or continue to endure the abuses of slavery.</p>
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		By: Retired Appraiser		</title>
		<link>https://appraisersblogs.com/appraisal-service-free-trade-suppression/#comment-16856</link>

		<dc:creator><![CDATA[Retired Appraiser]]></dc:creator>
		<pubDate>Mon, 12 Jun 2017 21:59:00 +0000</pubDate>
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					<description><![CDATA[In reply to &lt;a href=&quot;https://appraisersblogs.com/appraisal-service-free-trade-suppression/#comment-16619&quot;&gt;Lee&lt;/a&gt;.

Congratulations Lee, you made the only intelligent choice. This &quot;profession&quot; will never change for the better because it&#039;s infested with weaklings. Best of luck with your future endeavors.]]></description>
			<content:encoded><![CDATA[<p>In reply to <a target="_blank" href="https://appraisersblogs.com/appraisal-service-free-trade-suppression/#comment-16619">Lee</a>.</p>
<p>Congratulations Lee, you made the only intelligent choice. This &#8220;profession&#8221; will never change for the better because it&#8217;s infested with weaklings. Best of luck with your future endeavors.</p>
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		<title>
		By: Retired Appraiser		</title>
		<link>https://appraisersblogs.com/appraisal-service-free-trade-suppression/#comment-16855</link>

		<dc:creator><![CDATA[Retired Appraiser]]></dc:creator>
		<pubDate>Mon, 12 Jun 2017 21:56:45 +0000</pubDate>
		<guid isPermaLink="false">http://appraisersblogs.com/?p=14387#comment-16855</guid>

					<description><![CDATA[You have to love it when the mafia (AMCs) who have been extorting appraisers since 2009 are filing lawsuits because their monthly shake downs of customers is being restrained.

What&#039;s next? Rapists filing lawsuits against victims because they contracted a disease?]]></description>
			<content:encoded><![CDATA[<p>You have to love it when the mafia (AMCs) who have been extorting appraisers since 2009 are filing lawsuits because their monthly shake downs of customers is being restrained.</p>
<p>What&#8217;s next? Rapists filing lawsuits against victims because they contracted a disease?</p>
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		<title>
		By: marion		</title>
		<link>https://appraisersblogs.com/appraisal-service-free-trade-suppression/#comment-16687</link>

		<dc:creator><![CDATA[marion]]></dc:creator>
		<pubDate>Tue, 06 Jun 2017 04:07:21 +0000</pubDate>
		<guid isPermaLink="false">http://appraisersblogs.com/?p=14387#comment-16687</guid>

					<description><![CDATA[In reply to &lt;a href=&quot;https://appraisersblogs.com/appraisal-service-free-trade-suppression/#comment-16646&quot;&gt;Mike Ford, AGA, SCREA, GAA, RAA, Realtor®&lt;/a&gt;.

&lt;p&gt;Perhaps,&lt;/p&gt;
&lt;p&gt;It would open the eyes of many, if they reviewed the FTC case against Corelogic, and then realize, that 5 year time frame for providing make believe competition has already ended.&lt;/p&gt;
]]></description>
			<content:encoded><![CDATA[<p>In reply to <a target="_blank" href="https://appraisersblogs.com/appraisal-service-free-trade-suppression/#comment-16646">Mike Ford, AGA, SCREA, GAA, RAA, Realtor®</a>.</p>
<p>Perhaps,</p>
<p>It would open the eyes of many, if they reviewed the FTC case against Corelogic, and then realize, that 5 year time frame for providing make believe competition has already ended.</p>
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		By: Mike Ford, AGA, SCREA, GAA, RAA, Realtor®		</title>
		<link>https://appraisersblogs.com/appraisal-service-free-trade-suppression/#comment-16646</link>

		<dc:creator><![CDATA[Mike Ford, AGA, SCREA, GAA, RAA, Realtor®]]></dc:creator>
		<pubDate>Mon, 05 Jun 2017 13:23:22 +0000</pubDate>
		<guid isPermaLink="false">http://appraisersblogs.com/?p=14387#comment-16646</guid>

					<description><![CDATA[In reply to &lt;a href=&quot;https://appraisersblogs.com/appraisal-service-free-trade-suppression/#comment-16634&quot;&gt;Marion&lt;/a&gt;.

Marion, Lol! As long as your information doesn&#039;t get me in the dog house with Jan Bellas at AGA let them be jealous! You have always had great ability to lay  your hands on a plethora of public documents and regs.

I don&#039;t think the issue is whether there is any &#039;meat on the table&#039; for FTC...their certainly is. The issue is in this instance, whether they are misguided and acting in the best interests of the American Consumer and taxpayer, or whether this action may have been motivated by something else at a time when they only have two out of the mandated five Commissioners serving.

FIRREA never anticipated expanded or exclusive use of AMCs. That was Andrew Cuomo&#039;s brainchild arising from the Countrywide and WAMU settlement with his state. After great effort (some on your part I believe), Dodd Frank was passed with lip service token rules on appraiser independence and reasonable fees. Unfortunately it failed to provide any enforcement mechanism.

That is what Louisiana provided. As has Virginia. Strange it is Coester VMS and iMortgage that had problems in both these states, that is referenced in the FTC complaint.]]></description>
			<content:encoded><![CDATA[<p>In reply to <a target="_blank" href="https://appraisersblogs.com/appraisal-service-free-trade-suppression/#comment-16634">Marion</a>.</p>
<p>Marion, Lol! As long as your information doesn&#8217;t get me in the dog house with Jan Bellas at AGA let them be jealous! You have always had great ability to lay  your hands on a plethora of public documents and regs.</p>
<p>I don&#8217;t think the issue is whether there is any &#8216;meat on the table&#8217; for FTC&#8230;their certainly is. The issue is in this instance, whether they are misguided and acting in the best interests of the American Consumer and taxpayer, or whether this action may have been motivated by something else at a time when they only have two out of the mandated five Commissioners serving.</p>
<p>FIRREA never anticipated expanded or exclusive use of AMCs. That was Andrew Cuomo&#8217;s brainchild arising from the Countrywide and WAMU settlement with his state. After great effort (some on your part I believe), Dodd Frank was passed with lip service token rules on appraiser independence and reasonable fees. Unfortunately it failed to provide any enforcement mechanism.</p>
<p>That is what Louisiana provided. As has Virginia. Strange it is Coester VMS and iMortgage that had problems in both these states, that is referenced in the FTC complaint.</p>
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		<title>
		By: Pat		</title>
		<link>https://appraisersblogs.com/appraisal-service-free-trade-suppression/#comment-16644</link>

		<dc:creator><![CDATA[Pat]]></dc:creator>
		<pubDate>Mon, 05 Jun 2017 11:30:39 +0000</pubDate>
		<guid isPermaLink="false">http://appraisersblogs.com/?p=14387#comment-16644</guid>

					<description><![CDATA[The subpoenas are gonna fly!!]]></description>
			<content:encoded><![CDATA[<p>The subpoenas are gonna fly!!</p>
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		<title>
		By: EJ Brown		</title>
		<link>https://appraisersblogs.com/appraisal-service-free-trade-suppression/#comment-16638</link>

		<dc:creator><![CDATA[EJ Brown]]></dc:creator>
		<pubDate>Sat, 03 Jun 2017 20:12:13 +0000</pubDate>
		<guid isPermaLink="false">http://appraisersblogs.com/?p=14387#comment-16638</guid>

					<description><![CDATA[Yeah, 90% of all the REVAA member companies are on my DNU list. I wish they would quit sending me request &#038; BS emails.]]></description>
			<content:encoded><![CDATA[<p>Yeah, 90% of all the REVAA member companies are on my DNU list. I wish they would quit sending me request &amp; BS emails.</p>
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		<title>
		By: Marion		</title>
		<link>https://appraisersblogs.com/appraisal-service-free-trade-suppression/#comment-16634</link>

		<dc:creator><![CDATA[Marion]]></dc:creator>
		<pubDate>Sat, 03 Jun 2017 03:44:42 +0000</pubDate>
		<guid isPermaLink="false">http://appraisersblogs.com/?p=14387#comment-16634</guid>

					<description><![CDATA[Mike, now you&#039;re going to make everyone else jealous to tell them we&#039;ve spoken on the phone :)

But I&#039;ve spoken on the phone with others who have posted here to, over the years.

Anyway,
The FTC&#039;s website is a wealth of information, especially considering   certain AMC organizations, the mandating of the use of specific portals and tools, or background checking companies, on, and on, and on, to the point where you start to say to your self,  Ghee, there really might be something here worth pursuing.

Anyway, awhile back, I had collected some hard data from around the country for other &quot;interested&quot; parties, I had not thought about in awhile.  So because of this funny little FTC game, I&#039;ve decided to set aside some time this weekend to search for where I put it, and to contact those I had previously sent it to, to see if it&#039;s worth reviewing in the new light of day for a different intended use.  If my interest is increased by reviewing what I have, maybe I&#039;ll give you a call, or not, I won&#039;t know until I look back through what I have.

But I have some idea that there should be many appraisers that have, or had, emails saying that they had to sign up with XYZ to get work from ABC, and that is specifically addressed on the FTC website.]]></description>
			<content:encoded><![CDATA[<p>Mike, now you&#8217;re going to make everyone else jealous to tell them we&#8217;ve spoken on the phone 🙂</p>
<p>But I&#8217;ve spoken on the phone with others who have posted here to, over the years.</p>
<p>Anyway,<br />
The FTC&#8217;s website is a wealth of information, especially considering   certain AMC organizations, the mandating of the use of specific portals and tools, or background checking companies, on, and on, and on, to the point where you start to say to your self,  Ghee, there really might be something here worth pursuing.</p>
<p>Anyway, awhile back, I had collected some hard data from around the country for other &#8220;interested&#8221; parties, I had not thought about in awhile.  So because of this funny little FTC game, I&#8217;ve decided to set aside some time this weekend to search for where I put it, and to contact those I had previously sent it to, to see if it&#8217;s worth reviewing in the new light of day for a different intended use.  If my interest is increased by reviewing what I have, maybe I&#8217;ll give you a call, or not, I won&#8217;t know until I look back through what I have.</p>
<p>But I have some idea that there should be many appraisers that have, or had, emails saying that they had to sign up with XYZ to get work from ABC, and that is specifically addressed on the FTC website.</p>
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		By: Mike Ford, AGA, SCREA, GAA, RAA, Realtor®		</title>
		<link>https://appraisersblogs.com/appraisal-service-free-trade-suppression/#comment-16633</link>

		<dc:creator><![CDATA[Mike Ford, AGA, SCREA, GAA, RAA, Realtor®]]></dc:creator>
		<pubDate>Sat, 03 Jun 2017 02:27:08 +0000</pubDate>
		<guid isPermaLink="false">http://appraisersblogs.com/?p=14387#comment-16633</guid>

					<description><![CDATA[In reply to &lt;a href=&quot;https://appraisersblogs.com/appraisal-service-free-trade-suppression/#comment-16622&quot;&gt;Marion&lt;/a&gt;.

*s* Marion, since we&#039;ve already spoken by phone, please it&#039;s just Mike.

I think the FTC complaint is based on material Harry Truman was used to describing in colorful colloquialism to the chagrin of Bess. No one really believes the complaint was actually filed for the benefit of consumers, do they?

Consumers, &#039;The Public&#039; and taxpayers are just descriptions self serving politicos trot out to dress up what would otherwise be clearly spurious implementing rules of feel good legislation.]]></description>
			<content:encoded><![CDATA[<p>In reply to <a target="_blank" href="https://appraisersblogs.com/appraisal-service-free-trade-suppression/#comment-16622">Marion</a>.</p>
<p>*s* Marion, since we&#8217;ve already spoken by phone, please it&#8217;s just Mike.</p>
<p>I think the FTC complaint is based on material Harry Truman was used to describing in colorful colloquialism to the chagrin of Bess. No one really believes the complaint was actually filed for the benefit of consumers, do they?</p>
<p>Consumers, &#8216;The Public&#8217; and taxpayers are just descriptions self serving politicos trot out to dress up what would otherwise be clearly spurious implementing rules of feel good legislation.</p>
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		By: Baggins		</title>
		<link>https://appraisersblogs.com/appraisal-service-free-trade-suppression/#comment-16629</link>

		<dc:creator><![CDATA[Baggins]]></dc:creator>
		<pubDate>Fri, 02 Jun 2017 17:23:25 +0000</pubDate>
		<guid isPermaLink="false">http://appraisersblogs.com/?p=14387#comment-16629</guid>

					<description><![CDATA[In reply to &lt;a href=&quot;https://appraisersblogs.com/appraisal-service-free-trade-suppression/#comment-16616&quot;&gt;Marion&lt;/a&gt;.

&quot;So even if an appraiser will accept less, a management company can keep the difference&quot;, aka; cost savings from reduced costs of appraisal services are not returned to borrowing consumers, arguably a violation of the spirit of unearned fee and junk fee existing rule sets.]]></description>
			<content:encoded><![CDATA[<p>In reply to <a target="_blank" href="https://appraisersblogs.com/appraisal-service-free-trade-suppression/#comment-16616">Marion</a>.</p>
<p>&#8220;So even if an appraiser will accept less, a management company can keep the difference&#8221;, aka; cost savings from reduced costs of appraisal services are not returned to borrowing consumers, arguably a violation of the spirit of unearned fee and junk fee existing rule sets.</p>
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		By: Baggins		</title>
		<link>https://appraisersblogs.com/appraisal-service-free-trade-suppression/#comment-16628</link>

		<dc:creator><![CDATA[Baggins]]></dc:creator>
		<pubDate>Fri, 02 Jun 2017 17:20:42 +0000</pubDate>
		<guid isPermaLink="false">http://appraisersblogs.com/?p=14387#comment-16628</guid>

					<description><![CDATA[In reply to &lt;a href=&quot;https://appraisersblogs.com/appraisal-service-free-trade-suppression/#comment-16615&quot;&gt;Mike Ford&lt;/a&gt;.

&quot;and other loan brokers are trying to steal the deal&quot;.  aka; slam dunking customers with unnecessary and unethical emphasis on faster appraisal turn times.]]></description>
			<content:encoded><![CDATA[<p>In reply to <a target="_blank" href="https://appraisersblogs.com/appraisal-service-free-trade-suppression/#comment-16615">Mike Ford</a>.</p>
<p>&#8220;and other loan brokers are trying to steal the deal&#8221;.  aka; slam dunking customers with unnecessary and unethical emphasis on faster appraisal turn times.</p>
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		By: Marion		</title>
		<link>https://appraisersblogs.com/appraisal-service-free-trade-suppression/#comment-16622</link>

		<dc:creator><![CDATA[Marion]]></dc:creator>
		<pubDate>Fri, 02 Jun 2017 14:49:37 +0000</pubDate>
		<guid isPermaLink="false">http://appraisersblogs.com/?p=14387#comment-16622</guid>

					<description><![CDATA[Mr Ford,

Please consider consumers, the FTC and rushing in to save appraisers, that:

12 CFR 1024.14

RESPA Section 8(b) is not violated when a single party charges and retains a settlement service fee, and that fee is unearned or excessive.

&lt;a href=&quot;http://files.consumerfinance.gov/f/201503_cfpb_regulation-x-real-estate-settlement-procedures-act.pdf&quot; target=&quot;_blank&quot; rel=&quot;nofollow&quot;&gt;CFPB Consumer Laws and Regulations – Regulation X – Real Estate Settlement Procedures Act RESPA&lt;/a&gt;

Should a property qualify for an appraisal wavier, and the appraisal fee has been paid, the borrower is not harmed under RESPA if the &quot;appraisal&quot; is waved and the fee is not returned to the borrower.

If the loan qualifies for an &quot;evaluation&quot; and an appraisal fee has been paid, the borrower is not harmed if an &quot;evaluation&quot; is performed instead of an appraisal, and the fee, or difference in fees is not returned to the borrower.

Tread lightly, but carry a big media companion.]]></description>
			<content:encoded><![CDATA[<p>Mr Ford,</p>
<p>Please consider consumers, the FTC and rushing in to save appraisers, that:</p>
<p>12 CFR 1024.14</p>
<p>RESPA Section 8(b) is not violated when a single party charges and retains a settlement service fee, and that fee is unearned or excessive.</p>
<p><a target="_blank" href="http://files.consumerfinance.gov/f/201503_cfpb_regulation-x-real-estate-settlement-procedures-act.pdf" target="_blank" rel="nofollow">CFPB Consumer Laws and Regulations – Regulation X – Real Estate Settlement Procedures Act RESPA</a></p>
<p>Should a property qualify for an appraisal wavier, and the appraisal fee has been paid, the borrower is not harmed under RESPA if the &#8220;appraisal&#8221; is waved and the fee is not returned to the borrower.</p>
<p>If the loan qualifies for an &#8220;evaluation&#8221; and an appraisal fee has been paid, the borrower is not harmed if an &#8220;evaluation&#8221; is performed instead of an appraisal, and the fee, or difference in fees is not returned to the borrower.</p>
<p>Tread lightly, but carry a big media companion.</p>
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		By: Mike Ford		</title>
		<link>https://appraisersblogs.com/appraisal-service-free-trade-suppression/#comment-16621</link>

		<dc:creator><![CDATA[Mike Ford]]></dc:creator>
		<pubDate>Fri, 02 Jun 2017 14:04:02 +0000</pubDate>
		<guid isPermaLink="false">http://appraisersblogs.com/?p=14387#comment-16621</guid>

					<description><![CDATA[In reply to &lt;a href=&quot;https://appraisersblogs.com/appraisal-service-free-trade-suppression/#comment-16616&quot;&gt;Marion&lt;/a&gt;.

Marion if this blog had an HTML format I&#039;d give ya a big ol&#039; thumbs up! Can you settle for the little one at the bottom of your post?]]></description>
			<content:encoded><![CDATA[<p>In reply to <a target="_blank" href="https://appraisersblogs.com/appraisal-service-free-trade-suppression/#comment-16616">Marion</a>.</p>
<p>Marion if this blog had an HTML format I&#8217;d give ya a big ol&#8217; thumbs up! Can you settle for the little one at the bottom of your post?</p>
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		By: Mike Ford, AGA, SCREA, GAA, RAA, Realtor®		</title>
		<link>https://appraisersblogs.com/appraisal-service-free-trade-suppression/#comment-16620</link>

		<dc:creator><![CDATA[Mike Ford, AGA, SCREA, GAA, RAA, Realtor®]]></dc:creator>
		<pubDate>Fri, 02 Jun 2017 13:53:52 +0000</pubDate>
		<guid isPermaLink="false">http://appraisersblogs.com/?p=14387#comment-16620</guid>

					<description><![CDATA[In reply to &lt;a href=&quot;https://appraisersblogs.com/appraisal-service-free-trade-suppression/#comment-16619&quot;&gt;Lee&lt;/a&gt;.

Lee, funny you should mention that...

&lt;em&gt;American Guild of Appraisers &lt;/em&gt;noted in article is a &#039;true union&#039;. Oh, we don&#039;t act like a 1940&#039;s-1970&#039;s union where its a large smoke filled meeting hall with everyone yelling &quot;Strike! Strike! Strike!&quot; and threatening boycotts or walk outs...though admittedly sometimes its difficult NOT to suggest doing that.

&lt;em&gt;We have always looked for win-win solutions working within the regulatory framework that exists&lt;/em&gt; while at the same time trying to remain sensitive to the fact that traditionally appraisers are not your typical union candidates.

Some years ago I finally realized the solutions have to be national in scope rather than purely state by state despite the excellent progress a few states have shown (Virginia is an excellent example; North Carolina has made positive progress and up til this issue, so had Louisiana). I overcame my own Republican based reticence to join organized labor and became an organizer. (If you want a really fun hobby try becoming a union organizer as a Republican some time and to really endear yourself to all, announce that fact in public hearings). At least after the laughter dies down, neither political camp can attack for purely philosophical reasons!

Anyway, hopefully that disclosure makes it easier for some other traditional anti union hearts and minds to hold their nose and join the cause. We&#039;ve helped some members keep their licenses when falsely accused; or over-accused for nominal impact type errors.

As I&#039;m sure you know, getting any three groups of appraisers to agree on anything is only slightly less difficult than herding felines in heat through a forest full of Tom Cats. Progress is being made though.

Sometimes it&#039;s a case of three steps forward and two steps back; with interludes of one step forward and three steps back. Seeking solutions to our primary challenges is always a moving target. Add in a federal system (BOTH parties) that doesn&#039;t actually WANT to do anything and states that run the gamut from those that don&#039;t want to do anything at all for appraisers to those such as Louisiana that try to help appraisers and get blind-sided by a federal agency whose motives are at best &quot;suspect&quot;.

Im told this case started over a year ago during the prior administration that like to pretend it was consumer friendly. It&#039;s also an agency that is short a few Commissioners according to folks that have written me about it.

Whether the FTC should be involved or not isn&#039;t as much a concern as WHY the FTC believes suppressing fees to a point where low fee related quality is officially recognized through Dodd-Frank as suffering. Taxpayers and ALL American consumers ultimately always pay the price for the kind of substandard work ultra low, ridiculous fees promote.

In a few weeks the Guild will be authoring a detailed recap of an over a year state regulatory agency and resulting long court case involving exceptional documented misconduct and incompetence on the part of the state investigators. Any appraisers that believe they are immune to such a case because they do good work are in for a huge surprise. Worse that that, our case load over the past couple years indicates this is now commonplace!

Appraisers in every state need to find out (1) IF their state appraisal regulators are required to follow USPAP when investigating compliance with USPAP; (2) Whether their state investigators do out side appraisals, and if not, then when the last time was that they performed an appraisal as anyone&#039;s peer; (3) IF they are allowed to do loan production work then are adequate safeguards in place to prevent conflicts of interest from &#039;eliminating competition&#039;, and (4) find out what your states administrative law hearings allow in terms of mounting a defense.

Website Link is to the Appraisers Guild for those that didn&#039;t know such a guild exists. If you have not already joined, please consider it.

My website is still just my name &quot;www.MFFord.Com&quot;]]></description>
			<content:encoded><![CDATA[<p>In reply to <a target="_blank" href="https://appraisersblogs.com/appraisal-service-free-trade-suppression/#comment-16619">Lee</a>.</p>
<p>Lee, funny you should mention that&#8230;</p>
<p><em>American Guild of Appraisers </em>noted in article is a &#8216;true union&#8217;. Oh, we don&#8217;t act like a 1940&#8217;s-1970&#8217;s union where its a large smoke filled meeting hall with everyone yelling &#8220;Strike! Strike! Strike!&#8221; and threatening boycotts or walk outs&#8230;though admittedly sometimes its difficult NOT to suggest doing that.</p>
<p><em>We have always looked for win-win solutions working within the regulatory framework that exists</em> while at the same time trying to remain sensitive to the fact that traditionally appraisers are not your typical union candidates.</p>
<p>Some years ago I finally realized the solutions have to be national in scope rather than purely state by state despite the excellent progress a few states have shown (Virginia is an excellent example; North Carolina has made positive progress and up til this issue, so had Louisiana). I overcame my own Republican based reticence to join organized labor and became an organizer. (If you want a really fun hobby try becoming a union organizer as a Republican some time and to really endear yourself to all, announce that fact in public hearings). At least after the laughter dies down, neither political camp can attack for purely philosophical reasons!</p>
<p>Anyway, hopefully that disclosure makes it easier for some other traditional anti union hearts and minds to hold their nose and join the cause. We&#8217;ve helped some members keep their licenses when falsely accused; or over-accused for nominal impact type errors.</p>
<p>As I&#8217;m sure you know, getting any three groups of appraisers to agree on anything is only slightly less difficult than herding felines in heat through a forest full of Tom Cats. Progress is being made though.</p>
<p>Sometimes it&#8217;s a case of three steps forward and two steps back; with interludes of one step forward and three steps back. Seeking solutions to our primary challenges is always a moving target. Add in a federal system (BOTH parties) that doesn&#8217;t actually WANT to do anything and states that run the gamut from those that don&#8217;t want to do anything at all for appraisers to those such as Louisiana that try to help appraisers and get blind-sided by a federal agency whose motives are at best &#8220;suspect&#8221;.</p>
<p>Im told this case started over a year ago during the prior administration that like to pretend it was consumer friendly. It&#8217;s also an agency that is short a few Commissioners according to folks that have written me about it.</p>
<p>Whether the FTC should be involved or not isn&#8217;t as much a concern as WHY the FTC believes suppressing fees to a point where low fee related quality is officially recognized through Dodd-Frank as suffering. Taxpayers and ALL American consumers ultimately always pay the price for the kind of substandard work ultra low, ridiculous fees promote.</p>
<p>In a few weeks the Guild will be authoring a detailed recap of an over a year state regulatory agency and resulting long court case involving exceptional documented misconduct and incompetence on the part of the state investigators. Any appraisers that believe they are immune to such a case because they do good work are in for a huge surprise. Worse that that, our case load over the past couple years indicates this is now commonplace!</p>
<p>Appraisers in every state need to find out (1) IF their state appraisal regulators are required to follow USPAP when investigating compliance with USPAP; (2) Whether their state investigators do out side appraisals, and if not, then when the last time was that they performed an appraisal as anyone&#8217;s peer; (3) IF they are allowed to do loan production work then are adequate safeguards in place to prevent conflicts of interest from &#8216;eliminating competition&#8217;, and (4) find out what your states administrative law hearings allow in terms of mounting a defense.</p>
<p>Website Link is to the Appraisers Guild for those that didn&#8217;t know such a guild exists. If you have not already joined, please consider it.</p>
<p>My website is still just my name &#8220;www.MFFord.Com&#8221;</p>
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		By: Lee		</title>
		<link>https://appraisersblogs.com/appraisal-service-free-trade-suppression/#comment-16619</link>

		<dc:creator><![CDATA[Lee]]></dc:creator>
		<pubDate>Fri, 02 Jun 2017 04:48:19 +0000</pubDate>
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					<description><![CDATA[Appraisers really need to have a true union, just like any other industry. Everything that is wrong with this profession is byproduct of appraisers being passive, i personally, had enough and left the industry few months ago.  Not only are appraisers being paid low fees but are also subject to complains that anyone can make and report to state to fine and penalize poor appraisers. Why would anyone want to even enter this dinosaur profession is beyond me.]]></description>
			<content:encoded><![CDATA[<p>Appraisers really need to have a true union, just like any other industry. Everything that is wrong with this profession is byproduct of appraisers being passive, i personally, had enough and left the industry few months ago.  Not only are appraisers being paid low fees but are also subject to complains that anyone can make and report to state to fine and penalize poor appraisers. Why would anyone want to even enter this dinosaur profession is beyond me.</p>
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