The ever increasing demand on Appraisers in the last decade to meet unethical standards and requests have caused some Appraisers who once enjoyed this profession to slowly become bitter.
Undoubtedly these Appraisers feel a glimmer of hope because the newly revised HVCC restricts the use of "comp checks" (and other pressure based tactics) and enforces the payment of services rendered by Appraisers. For some, the good of these restrictions out-ways the downside of the possible loopholes that the newly revised HVCC has created and the drop in business that will occur from the natural migration from bigger banks to acquire services from appraisal management companies.
For some Appraisers this drop in business is the most important issue facing their business and will undoubtedly make an effort to use the comment period now in affect. But will comments on how appraisals are ordered have an affect or will it fall on deaf ears?
Since those type of comments were included before the newly revised HVCC was written (for a bigger part of 2008), some believe these comments as such will do nothing. Logic would suggest that only new types of comments will be considered because of the lack of resources and responsiveness the AG (as well as others) have shown.
For those of us that are disheartened by the loss in revenue, as well as the loopholes in the new HVCC: It would be appropriate to send strong support for the good aspects of the HVCC and provide strong commentation on the problems with it. It cannot hurt to provide commentation, but as a business owner it might also be wise to adjust our business model and appraisal practices that includes all the type of revenue needed to keep business at a healthy level.
Author: Aaron O. Thomas, Certified Residential Appraiser. Aaron is owner of San Diego Appraisers, a real estate appraisal service provider specializing in residential properties located in the greater San Diego County area. San Diego Appraisers service mortgage brokers, CPAs, lawyers, businesses and homeowners.