In the Matter of CoreLogic, Inc., a corporation, File No. 131 0199
As a professional residential real estate appraiser, the actions of CoreLogic in buying up various branches of the valuation industry alarms me greatly. I believe that the FTC's proposed actions regarding CoreLogic's actions and non-response is completely justified. A more serious issue however, is CoreLogic's actions to purchase other businesses that represent various branches of the valuation industry. CoreLogic's actions represent a strategic plan to dominate. The issue is not unfair competition -- as appraisers are typically users of many of CoreLogic's "products" , but the issue IS the integrity of the entire valuation process. CoreLogic's control of a variety of the property sales and information databases and search programs that appraisers depend upon for information on comparable sales and market conditions, such as REIS, Realist, AppraiserSuite, and RealQuest, constitute a dangerous precedent. In addition, CoreLogic provides flood zone certifications through FloodCert, and owns the leading provider of residential and commercial construction cost data, Marshall & Swift. CoreLogic also owns two of the "portals" for ordering and transmitting appraisal reports; FNC and Mercury Network. And NOW...CoreLogic has just acquired one of the largest and most popular appraisal software firms, a la mode. CoreLogic is the source of the automated appraisal review program LSAM, which is widely used by large and small lenders and appraisal management companies, not to mention the Veterans Administration VA Appraisal Portal which uses LSAM. CoreLogic also owns a national provider of appraisal education and symposia, Columbia Institute. And CoreLogic is a national appraisal management company, having purchased LandSafe and RELS. CoreLogic of course was also the subject of the FTC action with regard to its purchase of DataQuick Information System which relates to this request for comments. The effect of CoreLogic's expansion into all these areas is that ONE company controls the ordering of real estate appraisals, the data that the appraisers rely upon for their analysis, the transmission of the final reports, and the review of those reports. With it's aquisition of alamode,it now has access to the actual appraiser's reports of which it could easily farm data from without the appraiser's knowledge. The valuation of the collateral held to support a significant portion of the nation's mortgages is therefore in the hands of a SINGLE COMPANY. Appraisers, who are held to high standards of independence, objectivity,due diligence AND PUBLIC TRUST, are increasingly concerned about the inherent dangers of this concentration of control and its effect on the integrity, both real and perceived, of the valuation process. I URGE the FTC to examine this concentration and take appropriate measures to insure the safety and soundness of real estate transactions as well as to protect the public trust.