Subject: File Number 4-606 -- Enforcement of USPAP

August 30, 2010

In 1988 there was a huge S&L scandal involving fraudulent appraisals which caused TITLE XI to be born and the Uniform Standards of Professional Appraisal Practice (USPAP) to be formulated -- the Appraisal Subcommittee of Congress was instituted and the public, mortgage bankers, lenders, brokers have been fooled ever since - there has been no enforcement --

The idea was to put honest real estate appraisals into the industry as a result, protecting the appraisers and the public, but rather than enforcing the implementation, the ASC dallied around for 22 years and there is still no real enforcement. Even the new FinReg Law 111-203 list the following:

`(e) Mandatory Reporting- Any mortgage lender, mortgage broker, mortgage banker, real estate broker, appraisal management company, employee of an appraisal management company, or any other person involved in a real estate transaction involving an appraisal in connection with a consumer credit transaction secured by the principal dwelling of a consumer who has a reasonable basis to believe an appraiser is failing to comply with the Uniform Standards of Professional Appraisal Practice, is violating applicable laws, or is otherwise engaging in unethical or unprofessional conduct, shall refer the matter to the applicable State appraiser certifying and licensing agency.

So what!!! This merely means business is as usual and the crooks can operate at will as usual -- and the consumer public and the industry members lose.

I lost a 5 bedroom home with a pool, my mortgage was paid in full, my family was alienated, my marriage broke up, my 2 dogs were killed, $50,000 in legal fees and the home was illegally repaired without proper permits, and sold for $749,000 out of which I will receive nothing.

All of this because I insisted that the Leasehold interest be appraised under USPAP -- which 'they' turned into arbitration where appraiser/arbitrators may rule without enforcement of USPAP and have the blessing of the courts.

Enforce USPAP!!!

Best Regards,

Knud Lindgard