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As a small business owner and resident in Oregon, I am writing to you to ask your support for HB 3624-A. This bill would require Appraisal Management Companies (AMCs) to register with the Oregon Appraisal Certification and Licensure Board.

Real Estate Agents, Financial Institutions and Real Estate Appraisers are licensed and regulated by their state and the federal government. AMC’s are the only party to Real Estate Financial Transaction that are not regulated. Most importantly, they are outside the loop that protects the consumer and public trust.

Most of the larger AMCs are owned and operated by banks. In some instances, these AMC’s are profit centers for the bank and the profits are paid for by the consumer. It appears that due to the current economic crisis, the banks created a way to increase their bottom line through their bank owned AMCs. This is an example of the fox in charge of the hen house.

Our small businesses as appraisers, contribute to the overall economy, we pay our taxes, we pay for our licenses and business expenses in the State or Oregon, most of the AMCs are out of state and do not financially support our State. With regulation, the AMCs must pay a registration fee and will be monitored for the performance, to ensure that consumers of the State of Oregon are protected! Again, we need to foster the public’s trust!

Due to the advent of the HVCC adopted in May 2009, which was a settlement between the New York Attorney General and the GSEs (Government Sponsored Enterprises – Fannie Mae and Freddie Mac), the AMCs have experienced tremendous growth. The HVCC intentions were good, imposed the separation between the loan officer, loan processor and the appraiser, but had some very unfortunate consequences. Lenders felt the need for third party separation (hence an AMC), that caused increased fees to the consumer, required unreasonable turn times, appraisers that are not geographically competent and has affected the quality and accuracy that leads to a credible conclusion of value. Again, the consumer has been harme

Although, there is not a perfect solution to this issue, I believe that your vote for passage of HB 3624-A is a huge step in the right direction to protect the public trust! Enforcing the accountability of AMCs for their actions should be mandatory!

Thank you for your efforts in passing HB 3624-A.