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From: Anonymous Subject: Regulation Z -- Truth in Lending Comments: Date: Dec 23, 2010 Proposal: Regulation Z Truth In Lending Act Document ID: R-1394 Document Version: 1 Release Date: 10/18/2010

Truth in Lending has been a long-standing goal of mine, but due to the current status of appraisal, I know it is a long distance goal. The Truth in Lending Act would help accelerate this goal, by prohibiting the use of unethical, unscientific approaches by appraisers, appraisal management companies, appraisal firms, and other parties to the appraisal process. The Truth in Lending Act of 2010 provides for the following regulatory provisions which I respectfully submit to you for consideration: 1. Exemption Provision: This application is for an exemption from section 502 of the Truth in Lending Act, 15 U.S.C. § 1692. Exemption from section 502 of the statute may be granted only with respect to the appraisal activities of a professional appraisal management company. The applicant has demonstrated that it has obtained written consent from each appraisal management company that it controls and is the only appraisal management company that it controls. 2. Requirements of this Subpart: You must complete the Application for Exemption under the title “Exemption Provision” and include the following information as a complete and true statement of each and every provision that would preclude you from being exempt from the requirements of the Truth in Lending Act. The applicant will also be responsible for providing such documentation as the agency deems appropriate on a current basis. 3. Subpart D -- Standards of Exemption: The standards of this subpart require your examination and approval to determine the financial stability of your appraisal management company, and whether you are able to comply with the appraisal standards set forth in the Truth in Lending Act. In addition, the Standards of Exemption contain requirements to ensure the appraisal process remains reliable and fair, consistent with the public interest and the needs of consumers. It is understood that an appraisal can be relied upon or rejected as fair or unfair only after a thorough analysis with regard to the following: (a) Performance of the appraisal activities of the appraisal management company; (b) Financial stability of the appraisal operations of the appraisal management company; (c) Financial stability of the appraiser; (d) Financial stability of the appraiser client; (e) Risk of conflicts of interest with the appraiser; (f) Conflict of interest of the client in relation to a third party; (g) A reasonable degree of professional skill and experience of the appraiser and appraiser client, and a reasonable degree of professional competence or knowledge of the appraisal methodology; (h) Integrity of the appraisal process; 4.

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