Comment from Scamahorn, Kelli

TILA 129E should promote full disclosure on the actual fees paid to appraisers. If anyone actually looked at this, they would be disgusted. This is misleading to consumers and ultimately producing poor appraisal quality. There is no shortage of appraisers, just a shortage of appraisers willing to work for 1/2 the pay. This creates an environment where an AMC will spend sometimes weeks to shop around for a cheap appraiser willing to take a meager fee on an appraisal instead of paying a well trained appraiser to do an assignment. This artificially creates low appraisal quality as most appraisers willing to take low fees and fast turn times are cutting corners or poorly trained. It creates an unusual business model where fast and cheap win over quality and accuracy. As an appraiser of nearly 20 years, the Appraisal Management Company model has been a parasite on the backs of appraisers. When it first started, it was to separate appraisers from banks, which they did do to some degree. But they also took away appraisers rights to determine their own fees for appraisal assignments, and a race to the bottom among appraisers. AMCs usually take around 1/2 of the pay that would go to the appraiser for themselves and prioritize fast/cheap over experience and quality. This has left most of us with a pay cut over the years instead of a pay raise. On top of that, there are 6-8 large AMCs that control roughly 60-80% of all mortgage business in the united states. This greatly impacts appraisers ability to act independently when they are faced with leaving the profession or taking a pay cut to do work.