Comments on: Unintended Consequences of the Dodd-Frank Law and Potential Remedies

By: bubba jay

bubba jay — Mon, 18 May 2015 01:54:05 +0000

In reply to Mike Ford, CA AG, SCREA, AGA, GAA, RAA.

well said Mike. there might be a lot of good appraisers out there, but anyone who is doing appraisals for $300 or less and are not complaining about the fees being inappropriate, is lousy at running a BUSINESS. until appraisers figure that out . . . . .

the bleeding continues . . . . .

By: Mike Ford, CA AG, SCREA, AGA, GAA, RAA

Mike Ford, CA AG, SCREA, AGA, GAA, RAA — Sun, 17 May 2015 03:06:08 +0000

Not exactly a widespread consensus of appraisers.

I don’t want to shoot anyone’s efforts down, and these are far better than nothing, but they still leave all the loopholes for lenders and AMCs in place. They are still laudable goals overall.

Delete the meaningless word “customary” from ALL state and federal regulations. Replace it instead with only the work “reasonable” and then DEFINE that word and accompany failure to pay reasonable fees with fines of not less than ten times what the fee should have been!

My suggestion is ‘reasonable fees would follow the federal civil service pay scales for grades GS7 through GS 15 (with 14s and 15s being almost purely managerial appraisers) based on license levels and years of experience. Civil service has ALREADY DEFINED REASONABLE salaries for appraisers at all levels. Add in the state location premiums and factor in home office overhead, vacations, insurance and retirement and divide those by the number of appraisals an appraiser can do 100% USPAP compliant in a 40 hour work week and you have your “reasonable” fee minimums.

By: Tom D

Tom D — Sat, 09 May 2015 18:54:24 +0000

A 1 page paper by me. Pay the appraiser more money. All the years of listening to how we should improve the holiness of our profession. That concept worked really well.

By: Retired Appraiser

Retired Appraiser — Fri, 08 May 2015 18:38:33 +0000

I’ve always found the words “unintended consequences” to be laughable with regard to what took place. HVCC succeeded beyond their wildest dreams in accomplishing what they INTENDED it to do. It has poured tens of millions of dollars into the pockets of banks each year, for SIX LONG YEARS via their AMCs. You guys will be discussing remedies 20 years from now; long after the retirement of the last HVCC rape victim.

Disrespectfully

Retired Appraiser