The revised HVCC appears, to me, would not force mortgage brokers to use AMC's at all. It just appears to me that you have to hire or make your secretary an "office manager", send them to an appraisal class, and just make sure that they are on a salary and in no way, including bonuses, connected to commissions from actual loans. See section III paragraph C below. Larger companies would just have a larger appraisal ordering/reviewing department. Several large companies that use our company already have this in place, and are giving us the same fee as before! C. Any employee of the lender (or if the lender retains an appraisal company or appraisal management company, any employee of that company) tasked with selecting appraisers for an approved panel or substantive appraisal review must be (1) appropriately trained and qualified in the area of real estate appraisals, and (2) in the case of an employee of the lender, wholly independent of the loan production staff and process. Do any of you see this differently?