Comment:

I own a small Residential Appraisal Business in Columbus, OH. Columbus is one of the fastest growing cities in the Midwest with home values fluctuating over the years. Currently the year over year Median & Average Sales prices in the entire Central Ohio MLS are $215,000 and $181,000 respectively. Why do we need to raise the limits when a city like Columbus, OH average prices are not even at the $250,000 level. This increase can only help the banks and large AMC and not the consumer / Tax Payer. Why not use due diligence and not rush everything. All to save $100 when consumers are making the biggest investment in their lives and families lives. Raising the exemption from $250,000 $400,000 is a bad idea. See attached MLS data.

The idea of creating a hybrid appraisal product called an “evaluation” vs. “appraisal” is a bad idea. The proposed hybrid evaluation does not even require a licensed appraiser or certified appraiser. Who is doing the evaluation ? Who will this product benefit ? What is the big rush to increase the appraisal turn time from 5-7 business days to 24-48 hours. At least the real estate purchase contract may give the home buyer an out with the 3 day right if rescission ( Regulation Z ) if they determine the speedy & cheap evaluation is not accurate.

Uploaded File(s)(Optional)

CBRMLS.pdf: success

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“The government”, a misnomer in this instance.  The lenders write their own regulations in a revolving door system.  Lenders have never been and will never be keen to additional checks and balances.  Those who do not know history are condemned to repeat it.  Problems with lenders and money changers were one of the cornerstones for the American Revolution.  Same old tricks, different day.  The real problem is the general public actually trusts these organizations.  We’re living in the last days of failing consumer protection as the public continues to excercize institutional memory and prioritizes debt over personal financial security.  These protections being eliminated now had previously grew up around a different public mindset…  What’s in your wallet?

I believe the general public values the Appraisal Industry. We get requests from the public for many reasons, tax appeal, estate planning, what to list a property for FSBO, fair market for divorce, etc…….. Do you think the public would be willing to replace the traditional appraisal (same appraiser inspects the property, researches the market and provides a value with reconciliatio ) all to save $100 for a “evaluation”.

I can’t believe the government will approve this……….uggggh.

As for the lack of appraiser, there is not a lack of them it is that we want a fair fee and the time to complete a credible report.

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Office of the Comptroller of the Currency
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Washington, DC 20219
or
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