You can participate with the new appraiser independence regulations that are being crafted as a result of the Dodd-Frank financial reform bill.
http://www.fdic.gov/news/news/press/2010/pr10187.html
"To seek input from the widest audience possible, the public can submit views via email on how the FDIC should implement the new law. These comments will become part of the record and will be posted on the FDIC website. The public will also be able to sign up for a subscription service for receiving notices on major developments. The FDIC has also crafted bill summaries and added a fact sheet that will be regularly updated to reflect policy decisions during the implementation process. This can all be accessed at the dedicated financial reform webpage, http://www.fdic.gov/financialreform/ "
If lots of independent appraisers provide comments, the more likely it will be that your (and our) concerns will be addressed.
If you think direct client ordering of appraisals can be implemented, provide specific methods to do that which will preserve your independence but still allow business relationships.
If you don’t like that idea, then aspects of the current HVCC may be mandated – which will not help your business environment. Remember, the ‘commerce’ section of the HVCC actually had its beginning with FIRREA in 1989. Times change.
AUTHOR: Dave Towne Towne Appraisals & Appraiser Education Service, Mount Vernon, WA
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