In the Matter of CoreLogic, Inc., a corporation, File No. 131 0199
Thank you for the opportunity to comment on the pending purchase of A la mode software by Corelogic. As a user of both companies products, this transaction concerns me in the end-to-end monopoly in the residential real estate appraisal process that Corelogic is acquiring in this purchase. Corelogic currently owns two prominent appraisal ordering portals (Mercury Network and Appraisal Scope), operates many multiple listing services across the country, owns cost data service provider Marshall and Swift, and provides public records data as part of their MLS systems. Adding A la mode under their ownership would create one company that controls the ordering mechanism; data sources for sales, rental, and cost data; and the appraisal production and delivery software for a large percentage of residential appraisals in the United States. I believe that control of these aspects of the appraisal process is an inherent conflict of interest and could potentially adversely affect consumers in the form of increasing prices to appraisers, which will be passed to the consumer. I also believe there is potential for harm to the public trust in appraisal services, should Corelogic leverage the end-to-end monopoly to impose changes on the appraisal industry such as limited scope of work appraisals (evaluations). These types of appraisal products often require less verification of data and facts, rushed turn around times, and significantly reduced fees, which in turn would result in lower quality appraisal services for consumers, increasing risk to borrowers and lenders alike. I strongly encourage you to evaluate the potential risks in Corelogic owning the appraisal process from ordering the appraisal to providing the data utilized in appraisals through report development and delivery. I believe that control of the appraisal process will negatively impact consumers. Thank you for your time and consideration.