Comment on CFPB-2012-0039-0001

Document ID: CFPB-2012-0039-0004
Document Type: Public Submission
Agency: Consumer Financial Protection Bureau
Received Date: November 27 2012, at 12:00 AM Eastern Standard Time
Date Posted: November 27 2012, at 12:00 AM Eastern Standard Time
Comment Start Date: November 7 2012, at 12:00 AM Eastern Standard Time
Comment Due Date: January 7 2013, at 11:59 PM Eastern Standard Time
Tracking Number: 1jw-827s-redt
View Document:  View as format xml

This is comment on Proposed Rule

Truth in Lending (Regulation Z)

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I have 2 suggestion on appraising real estate. 1. On FHA and VA loans the appraisal should follow the buyer not the property. This is unfair to the seller of the property that a potential buyer has the lender ask for an appraisal on subject property which is one persons opinion and the sale does not go thru because of value. Then the FHA appraisal stays with the property for 6 months and that does not allow the seller to sell it to any one else under an FHA loan unless they sell it for that original value that the first appraiser put on the property. This is not fair at all to the Seller. 2. I think to be fair to all parties(lender, buyer and seller) that if a property does not appraise by the first appraiser, if the seller or buyer wants to pay for a second appraisal that the lender can request another appraisal. Then if they are within 5% of each other they can avgerage the 2 together and make the loan. If they are not within 5% a 3rd appraisal could be ordered and the bad appraisal be thrown out. This would make it fair to all parties and it would not be based on one persons opinion. Thanks, Ben Yates, Realtor

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