A regulation requiring customary and reasonable fees is mandated by the failure of the government and banking and real estate industries to provide protection in the form of reasonable compensation to real estate appraisers.  After decades of receiving fees from $350 to $600 for appraisals, we are now asked to work for $200 to $250 while the AMC pockets the remainder.  Veterans Affairs (VA) appraisals are still at $350.  Appraisal fees have not decreased, the AMC is just taking 50% or more.  As a result, those appraisers who are least competent and will do the work for the lower fees are getting the work and producing lower quality products.  The entire industry has suffered, and will continue to do so unless the government steps in and makes these AMC's pay reasonable fees.  $350 is minimal.  For larger properties above 4,000 square feet of gross living area, it should be significantly higher, $450 to $600.  Anything less is a disservice to the profession.

In addition, it should be stated on all appraisals what actual fee was received by the appraiser, and how much went to the AMC.  What you immediately see is that the client (homeowner, bank, etc.) is still paying a fee of $400 to $600 while the AMC pockets 50% or more while hiring the lowest bidder to do the appraisals.  The best appraisers who can afford to quit are leaving the industry or performing appraisals that are not mortgage-related.  The best appraisers who cannot afford to quit are getting kicked in the teeth.  Only the AMC profits, as well as some lenders, since the lending institutions often own the AMC as well.  Like everything else, government intervention, starting with Andrew Cuomo as the former New Your attorney general attacking Fannie Mae, has resulted in the destruction of a program and process that was working properly.  AMC legislation is crucial. 

Thank you.