Comment from Fancher, Bryan

I’m a residential appraiser. Certified in texas. My comment is on fees. The fee the consumer sees is one that is combined amc fee and appraiser fee. The AMCs are taking $200-$350 per order. It appears they race to the bottom taking the lowest quoted fee to make sure they can pay their people then their fee gets bunched in with the appraisers fee. The public need to know how much an AMC makes by choosing an appraiser. Having AMCs give out the work to appraisers allows AMCs to control who gets the work. This could lead to the suppression of appraisal fees, or all the work given to the appraiser who quotes the least. Appraisal fees have not risen with inflation, this leads to less appraiser taking on trainees, (they cannot pay them) and reliance on finding ways to cut corners to mass appraise quickly to keep profitability. Now with 3.6 rolling out, lenders do not want costs to go up even though the time to write a 3.6 is longer than prior forms. I also take issue with AMCS having staff appraisers. Thank you for hearing me out.