In the Matter of CoreLogic, Inc., a corporation, File No. 131 0199 #00139

Submission Number:
00139
Commenter:
Barry Wilson
State:
Washington
Initiative Name:
In the Matter of CoreLogic, Inc., a corporation, File No. 131 0199
Re: In the Matter of CoreLogic, Inc., Docket No. C-4458 April 16th, 2018 To whom it may concern, I think the FTC's proposed actions regarding CoreLogic's non-responsive actions is fully justified. However, of more serious concern, is the increasing presence and potential dominance CoreLogic has in the real estate collateral valuation process. I have been a residential appraiser in the Pacific Northwest since 1986, and I was a mortgage loan originator and a real estate broker prior to that. I have experienced the ups and downs of our industry for over 40 years and what worries me the most is the dominance of one entity, CoreLogic, in many sectors of our industry. Presently CoreLogic controls 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. CoreLogic provides flood zone certifications through FloodCert. CoreLogic owns the leading provider of residential and commercial construction cost data, Marshall Swift. CoreLogic owns two of the "portals" for ordering and transmitting appraisals, FNC and Mercury Network. CoreLogic has just acquired one of the largest and most popular appraisal software firms, Alamode. CoreLogic is the source of the automated appraisal review program LSAM, which is widely used by large and small lenders and appraisal management companies. CoreLogic also owns a national provider of appraisal education and symposia, the Columbia Institute. Finally, CoreLogic is a national appraisal management company in and of itself, having purchased both LandSafe and RELS. CoreLogic of course was also the subject of the FTC action with regard to its purchase of DataQuick Information System and this request for comments. Given all the above, CoreLogic controls nearly every aspect of real property valuations! They control ordering real estate appraisals, the data that the appraisers rely upon for their analysis, including comparable data, flood data and the platforms the data is on, transmission of the final reports, and the internal review of the appraisal reports via appraisal review software. 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 -- CoreLogic. As an appraiser, subject to high standards of independence, objectivity, and due diligence, I am increasingly concerned about the inherent dangers of this concentration of control by a single entity and its effect on the integrity, both real and perceived, of the valuation process. Based on this, I strongly urge the FTC to examine this concentration and take appropriate measures to insure the safety and soundness of real estate transactions. The federal government broke up the dominance of Standard Oil over the oil industry in the last century, now one company is trying to dominate the real estate industry. It is time to rein in CoreLogic. I thank you for the opportunity to provide these comments. Should you have questions, I can be reached at [redacted] or via email at [redacted]. Barry C Wilson Certified Residential Appraiser [redacted]