The newly passed HVCC bill is a big problem for the independant real estate appraiser.
The most qualified, best-educated, most experienced appraisers will not be the ones willing to accept the cut-rate fees, 48-hour turn-around times and net 30 payment terms offered by the as-yet unregulated AMCs. More likely than not, it will spawn appraiser "trainee mills" run by unscrupulous appraisers. They send trainee appraisers out to inspect the property and write the report (passing themselves off as the licensed appraiser, even sometimes wearing the appraiser's name tag). The licensed appraiser then reviews and signs the report, fraudulently asserting that they personally inspected the property. This type of fraud was rampant during the last boom and will very likely become common again in this AMC scenario.

Appraiser independence is crucial. However, how can we expect to achieve this by handing the power over to AMC's often wholly-owned by the banks who will benefit financially by the loan closing successfully. Aren't we just creating a new source of pressure on appraisers? Doesn't this sound more than vaguely similar to the Wamu-EAppraiseIt scandal that prompted Mr. Cuomo's initial investigation?
The increased hit to the consumer's wallet, the decrease in quality of mortgage appraisals and the delayed recovery of the real estate industry are the three biggest unintended casualties of this ill-advised plan. The harm caused to tens of thousands of small appraisal firms is additional collateral damage that remains unaddressed.

Best regards,



Thank you,

Bob Parsons

RWP & Associates Inc.
694 Grand Ave.
Elgin, Il 60120
p-847-343-4226
f-866-296-8488