The commenter argues that the current "0% tolerance fee rule" and disclosure requirements allow Appraisal Management Companies (AMCs) to suppress appraiser fees and deceive consumers. They advocate for reworking these rules to allow for a free market where appraiser fees are transparently separated from AMC fees and reflect the actual complexity of the work.

The commenter, likely an appraiser or representative of the appraisal profession, argues that the current "0% tolerance" fee rule and disclosure requirements are deceptive to consumers and harmful to appraisers. They advocate for reworking these rules to allow for a fluid fee structure that clearly separates the appraiser's compensation from the Appraisal Management Company's (AMC) fees.

Peg Peterson, a certified appraiser with 43 years of experience, supports the proposed action to prevent Appraisal Management Companies (AMCs) from bundling their fees with those paid to appraisers. She argues that this practice allows AMCs to reduce appraiser pay without proper disclosure.

The commenter argues that the combined fee disclosure and the 0% tolerance for appraisal fees should be repealed. They claim these measures allow lenders and AMCs to suppress appraiser compensation and ignore property complexity, which hinders the training of new appraisers.