Send a strong message asking
"Who gains from this proposition?"
1)
Do the big box banks gain? Yes.
because then they have additional leverage to drive down what their "pet" AMCs pay for "appraisals" and thus they can reap even more profits.
2)
Do Real Estate Agents or Mortgage brokers gain? In general, no.
because these are unregulated valuations they will typically be performed by only a few BPO specialists cranking out up to 30 reports per day for $10 - $30 per report.
3)
Will the general public gain? No.
because they will pay just as much for a unregulated product that does not have to comply with USPAP and that is being cranked out in 10-15 minutes per report, much like robo-signing.
4)
Will the little banks gain? No.
because they if they rely on these reports they will end up in trouble with federal regulators when the mortgages default and so forth.
5)
Will appraisers gain? No.
because there will be significantly less mortgage work to go around.
6)
Does the state or general public gain? No.
because substandard reports negatively affect lending, increase the probability of foreclosures, and would serve to further destabilize local economies.
There is already a mechanism in place to allow real estate agents and brokers to do valuations for lending, it is called becoming a state licensed or state certified appraiser and my information is that we already have a glut of them on the market and thus most probably consider it "not worth it" to go through many more hours of training than it took to get a RE sales license to do property evaluations, which should be telling.
I hereby give Terrel or any other Arkansas appraiser permission to use this post and send it to the state as written or rewritten in their own words. -D. M. Zwerg, Jan 25th, 2011 
