Comment on CFPB-2012-0031-0018

I am not understanding why the additional appraisal requirements would fall under the CFPB when the additional appraisal will be a cost that the borrower will have to absorb and does not offer any real additional protection to the borrower. If required on high priced loans (which our company stays away from) it only makes the loan a higher priced loan, which does not benefit the borrower. If the extra appraisal was just required for actual High Risk Loans such as less than 6 month resell of properties, that would be a prudent safe practice for the lender, but not really a benefit to the borrower. Our company recommends two appraisal when less 3 months resell, but the. 2nd appraisal can be waived, saving the consumer money, if various other less expense appraisal tools are used and the quality of the original appraisal with very strong comparables that are above average exist. In short, the 2nd appraisal and higher costs to the consumer should not be something the CFPB should be in the middle of, as it should be left to the Agencies, Investors, Lenders and their underwriters