Comment on CFPB_FRDOC_0001-0145

Document ID: CFPB-2012-0033-0020
Document Type: Public Submission
Agency: Consumer Financial Protection Bureau
Received Date: September 18 2012, at 12:00 AM Eastern Daylight Time
Date Posted: September 18 2012, at 12:00 AM Eastern Standard Time
Comment Start Date: September 17 2012, at 12:00 AM Eastern Standard Time
Comment Due Date: October 9 2012, at 11:59 PM Eastern Standard Time
Tracking Number: 8111ca05
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Providing a copy of the appraisal report by an end user (a lender) to third parties (borrowers) would be adding another burden to already over burdened appraisers and leave them even more vulnerable to frivolous complaints and law suits. The report a lender orders is for that lender's own use in determining mortgage liability. It is not intended for use by other third parties such as borrowers who may not understand appraisal principals, techniques and practices. Copies of reports should at minimum be accompanied by a disclaimer that the report is not for use for anything but determining mortgage lending liability by the stated lender/user. This is a bad idea that will eventually increase the appraiser's liability insurance and will ultimately raise the cost of appraisals to the borrower.

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