In the event that it is rejected, I think a good back up plan is to comprise a list of minimum changes to submit, that we deem necessary, in order to make at least the most minimal of changes, that would be needed to assure to some extent, reliable, impartial valuations.
If they are not ready to accept revamping a good part of the system, then at least we can recommend a number of specific changes, that would have some affect in correcting some of the systems most inadequate operations.
Obviously, appraisal ordering is one of them.... we have all thrown in our two cents in, in regards to specific changes, that are smaller then revamping the whole system.
One of the ones I had mentioned is that in the 7-8 years since lenders have been allowed to add to our 3rd party fee, it had enabled them to make quite a profit off our fees. With this situation, there will never be an incentive in the short run, to move away from the cheapest possible appraisal fee, and thus, perhaps in an inadequate appraisal, if it is such a profit center for them. IMO, this is huge ! As long as legislation allows them to do this, they will always seek the cheapest appraisal, and nothing will change. We need legislature that goes back to handling it as an absolute 3rd party fee, just like the others..
Just as example of my input..... but perhaps we should comprise a secondary proposal of such recommendations, that on a smaller scale, could still indoctrinate some very important changes, just in case they do not accept the proposal in it's entirety.