AMC Fees Exceeding Appraiser’s Fee

AMC management fees exceeding the appraiser’s fee more frequently

Over the past year, the AMC industry growth model – taken from the backs of residential appraisers – has been broken by a growing number of residential appraisers that won’t accept fees below the custom & reasonable rate. So in order for AMCs to grow revenue, appraisers are seeing their fees surpassed by the AMCs themselves. In other words, hiring the valuation expert – the whole point of getting an appraisal to begin with – to make less than the company that manages them. We hear the GSEs and lending industry complaints that appraisal fees are getting too high so they need to automate, yet the valuation expert doesn’t share in that gain – it’s all due to the wildly bloated institutional middleman.

The AMC is there to order the appraisals, do a simplistic review without local market knowledge, run analytics using tainted AMC feedback loop data, add unnecessary clerical scope, have 19-year olds chewing gum hound the appraiser every day for status and then follow up with addenda requests that have nothing to do with the quality of the valuation.

What other industry pays the paper-pushers more than their actual experts but the experts get blamed for being too costly? It’s bizarre and unfair to any industry and we are vulnerable because we are without any political might.

In order to save the consumer money, the actual valuation expertise is now being pulled out of the process with the introduction of “No Appraisal” waivers through the GSEs. I’m not saying there can’t be situations that it might be pragmatic, but the pattern has been laid out by the last 8 years of AMCs inserting themselves into the mortgage process. Are we over reacting? Of course not. The appraisal industry cannot trust the mortgage system to be self-correcting. If there was not a federal backstop, lenders themselves would take more interest in their respective mortgage process that is ultimately stamped with their name.
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AMC management fees exceeding the appraiser’s fee more frequently

Jonathan Miller

Jonathan Miller

President & CEO at Miller Samuel Inc.
Jonathan Miller is President and CEO of Miller Samuel Inc., a real estate appraisal and consulting firm he co-founded in 1986. He is a state-certified real estate appraiser in New York and Connecticut, performing court testimony as an expert witness in various local, state and federal courts.
Jonathan Miller
Image credit Mark J Skapinetz via Twitter
Jonathan Miller

Jonathan Miller

Jonathan Miller is President and CEO of Miller Samuel Inc., a real estate appraisal and consulting firm he co-founded in 1986. He is a state-certified real estate appraiser in New York and Connecticut, performing court testimony as an expert witness in various local, state and federal courts.

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25 Responses

  1. Michael Curtis, RM, SRA says:

    This is such a crock. The public thinks that WE are the ones getting rich. Just as I suspected; middle men are taking our money, while we do all of the work and take all of the risk and have to wait forever to get paid. The reason management companies exist is that a lot of appraisers are good at doing appraisals, but lousy at business; appraisers did not take care of their clients, so management companies saw an opportunity and took advantage of it. There are good management companies out there that pay reasonable and customary fees that don’t gouge the consumer. I work for one of them (MountainSeed) doing compliance reviews. From what I have seen from doing these reviews is that the more the appraiser gets paid, the higher the quality of work. When I see a low fee on an engagement letter, I know that I am going to be in for a lot of extra work and end up showing them how to fix their sloppy work product. The one’s who refuse revision requests get failed. The response is always the same, “I have been doing it this way for X # of years and nobody has ever said anything”.

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  2. Jack Of All Trades says:

    AMC = Scam Artists

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  3. Tim says:

    Just saw one of my previous AMC’s (who is owned by the exact mortgage company doing the loans) raised their theft of fees by $85.00 and not a penny MORE to the appraiser. BTY I calculated that if this mortgage company never ever closed one loan in an entire year, they would have still stolen about $1.3M from our fees. Not bad. Just set up a different corporation and you can say that their AMC has nothing to do with our mortgage process BUT, the money goes in the very same bank accounts of the owners at the end of the month. LET CONGRESS DO SOMETHING ABOUT THAT SHIT. IN THIS CASE, MONEY TALKS AND BULLSHIT IS HIDDEN.

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  4. Retired Appraiser Retired Appraiser says:

    You must understand however the level of difficulty involved in hitting a send button to broadcast orders across America searching for the lowest bid on an appraisal order.

    Great article!

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  5. Koma says:

    I’d rather eat dog food before accepting a fee below what I charge! Next crash is coming and it WILL be because of these AVM’s and the PIW. Believe Me.

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    • Tom D says:

      you have it backwards. the majority of appraisers ‘are willing’ to eat amc dog food. you can make a decent living by picking, and serving clients, not big amc’s. i paid the price. funny, but not that i retired, i’m working 8 days a week making pretty good money. of course not like 30 years ago, that was the golden age of appraising.

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  6. Tom Molinari says:

    Its just a bad system. Really bad. Apparently the market will pay $550 to $600 for a standard tract home appraisal. But no one is willing to pay the appraiser doing the appraiser that much. I do not do AMC work. I only work with lenders who pay full fee and have in house review appraisers. The AMC system was put in place to separate the appraiser from communicating with LOs. But guess what. The easiest way to get on an AMC list today is to ask your local LO to recommend you. The AMCs maintain individual “preferred appraiser” panels for individual mortgage companies. And you don’t get put on that list by being independent and producing quality appraisal reports. The whole AMC system is a scam to give the appearance of separating appraisers and LOs. And some of the largest AMCs in the nation are guilty of this practice. It’s time that they get called out but many appraisers are afraid to step up to the plate for fear of being blackballed. And, I don’t doubt that AMCs pay major kickbacks to Mortgage brokers to secure their appraisal business.

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  7. Chris says:

    You cant beat the banks !!!

    Stop letting it bother you !!!

    Just write your appraisals, stick to YOUR fees, and tell the rest to go fuck themselves.

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  8. Dave says:

    Wouldn’t it be great if the government passed a similar law saying people had to use Attorney Management Companies to hire an attorney. An attorney would no longer be allowed to directly engage an client, but would have to get work through an AMC- Attorney Management Company and would only get the job if they were the cheapest and fastest.  I wonder how long that would last….

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    • Wayne Courtney says:

      Dave, a search on the internet indicated that as of 2016 there were 1,315,561 lawyers in the US. As of the end of 2016 there were 73,731 appraisers with only 51% of these appraisers preparing residential reports. I have always said that Appraisal Management Companies cannot manage appraisers if they do not have any. I have not worked with any AMC in over a decade although I get requests from them every week.

      Appraisers do not need any new laws. We do not need permission from anyone. All we have to do is stop working with AMCs and the problem is solved. Some will say “WE CAN’T DO THAT!” I say that I do exactly that everyday, so I am positive that it can be done!

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      • Baggins Baggins says:

        I’ve got a very special tagline for this line of conversation; I’ve never before seen such a large group of ‘managers’, whom can’t make management decisions without someone elses approval or agreement.

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  9. Great article Johnathon.

    I’ve found that if we do not understand the true motivation of opponents, its next to impossible to reverse inequities.

    I’m not going to get political except to say that BOTH parties thrive on dissembling; lying, sound bites, and rumors designed to distract folks from the real or critical underlying issues. (PLEASE lets no go partisan on this-comment is illustrative only)

    The American Bankers Association and Mortgage Bankers Associations both exist solely to generate revenue by originating loans. Preferably loans that are insured so that they can be easily bundled and sold as bulk securities.That is what banks do. Lend other peoples money (now, anyway).

    FNMA and to a lesser extent Freddie are their facilitators. The entire process is to funnel insured loans to Wall Street for national and international investors. FIRREA was inconvenient to this process. So over 25 years most of it’s best provisions were either stripped out or the implementing regulations reinterpreted so that compliance could be easily side stepped.

    Just as the S&L crisis was attributed to appraisers; so too were TARP I; II and QE related recession. SOME knee jerk solution had to be found and appraisers were once again ‘convenient.’ Not bad loan policies or programs, but the appraiser. Particularly those that worked for Countrywide or WAMU. Hence HVCC. Nice, knee jerk and convenient ‘solution’.

    Once HVCC was shown to be a fraud, it was replaced with Dodd Frank WITHOUT teeth! More ‘follow the shiney baubles’ legislation. Frankly it WAS bad legislation though not for the partisan reasons always in dispute. More because it was simply written so poorly that it was not pragmatic. It could not be implemented without destroying localized political centers…er small banks; local political party donors. The part about C&R fees for appraisers was little more than a footnote and not worthy of enforcement.

    Again, lets keep it non partisan. BOTH sides want easy credit, with maximized volume lending. They only argue about the illusions of safety and protection of taxpayer/consumers. Neither side wants to see the volume of loans reduced anymore than they want to see federal agencies revenue reduced.

    THAT is the environment professional appraisers exist in. We are an inconvenience. Another obstacle to be side-stepped.

    GSE’s purportedly account for $five trillion in loan originations.That is barely one third less than the entire worth of Wall Street stocks (17T+?); and about the same ratio of total value of all American real estate. If ONLY the median value were used to calculate appraisal costs (eff 08/31/17; $253,500) and each appraisal was only at the VA rate of $600 the total cost of appraisals would be $11,800,000,000…Eleven point eight billion dollars.

    But the actual cost is higher than that; on average AMC fees are $650 to $750. CoreLogic alone generates revenue of over 1.5 billion a year. In order for banks to ‘get their cut’ and CL to get theirs; someone ELSE has to take less. They have the politicians ears, so it wont be them.

    For awhile it was us (via the AMCs), but now, even that is too expensive for the porkers to ‘give away’. By giving away, I refer to ANY revenue a bank or affiliate COULD claim whether earned by them or not…much like ATM ; or even government automated payment “convenience fees.” The systems were originally put in place to save banks & government users personnel overhead; but once consumers became to rely on ATMS and automated payments banks only saw lost potential revenue.

    The same holds true with AMCs; appraisers, and full appraisals to protect the public, taxpayers, consumers and professional investors alike. Since it is ONLY THE ILLUSION of protection that is important…

    CHEAPER alternatives are available.

    The ‘enemies’ of appraisers and consumers alike are not generically all AMCs. It is the dishonest backers and operators of some of the larger ones, and a scattering of smaller under funded ones using the big boys model.

    Hold to the high standards of USPAP, no matter what else comes down the pike. TAF is offering webinars (for a fee) to show how evals can be done according to USPAP. Just remember, USPAP compliant evals are NOT what the lenders and GSEs are seeking. Don’t get sucked into doing non compliant ones, no matter what.

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  10. Whats a solidifi font? Though I think most agree with second part of post.

    If you worked for solidifi send me private email and I’ll connect you to attorney that was looking for people that worked for solidifi. Same folks that got the class action settlement against Countrywide-BofA .

    Unrelated- is Haymarket Quarry still there? If so, does it still have the submerged school bus down around 35 to 50 feet deep. We used to use it for SCUBA diving training. Circa 1974. Snow on the ground.As long as no ice on top we went in…that water was COLD!

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  11. Xpert says:

    Yup, definitely Solidifi. Saw this posted the other day for a driveby request from Corelogic, another scum amc

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    • Baggins Baggins says:

      In CO they have preferred panels and min panels.  Some appraisers are getting 750 standard from them.  The national amc’s have this data and this is a key point why they won’t disclose national fee surveys, open the books to prove fairly balanced payment, etc.  It’s unlikely that our cost of living in Colorado is literally twice compared to the location of this articles fee data.

      Paper rules!  My order is stapled on paper to a manila folder with each and every order, on clipboard.  When I’m reviewing data with owners and talking for a moment, the standard deal is to show my order, fee and due date always highlighted.  It’s art of the deal and appraisers who can’t sell themselves have no business judging the sales terms and pricing points of others.  Appraisers should be expected to be superior sales terms analysts, claiming non advocacy as the ultimate defense.  I never have understood the value amc’s supposedly provide because being a decent salesman myself, being thusly qualified to take on the high responsibilities involved with non advocate analysis of terms and value, I can’t grasp the concept of needing help to sell my service.  It’s an easy sell; Triple whammy method;  call, email, online app.  All at once, take notes, qualify, repeat.  I can land a new direct client in a week flat if necessary, and I flip them for the next if they treat either me or their own borrowing customers poorly.  On an additional confidence inspiring note; the amc’s sales guys are really weak, they compete by price not quality.  Easy to upsell against those guys.  They blew the money on tech, not quality sales people.  Amc’s should have hired appraisers to do the selling, they dropped the ball big time. Knowledge is power.

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  12. Baggins Baggins says:

    Appraisers are oftentimes very charitable people. Apparently they don’t mind sharing that much fee. If the appraiser agrees to share, that’s their business decision and nobody makes them do it. I’ve been at 550-650 for around 2 years now. Amc’s still ring and email now and then, still shopping, still pushing 400’s and such. Even if they were to pay C&R, unless they have a direct consumer to appraiser fee relationship or higher standard flat fees, the engagement can be ethically problematic. During the high point I did confirm via multiple direct private conversations with amc staff persons; They are having to drive down fees in some locations to cover the spread difference for higher cost appraisal services in states like tx, or, and co. That’s very closely aligned with taxation without representation and robbing peter to pay paul. For years there has been an idea out there that amc’s have gifted the appraisers an immeasurable gift not yet realized, but easily realized with some simple operational method changes. They have done what appraisers could not do by themselves, raised the lenders average fee expectation and this is now reflected nationally on disclosure forms, a higher fee. All that appraisers need to do is sell the lenders directly and that fee increase is now theirs. If focus were to be on legislation the powerful and effective approach would be simply to define C&R as the total appraisal fee as disclosed on hud 1 forms. Remember how fiercely the industry lobbied to keep the improperly co mingled fees on a single line for the new hud 1 form? Remember viewing the sample hud 1 proposed forms, and how the ones which were not selected did in fact have separated disclosure for amc and appraisers fees? The mistake of the century, now capitalize. Appraisers are the valuation specialists and the task of understanding our own values is a necessary appeal. Price is not the same as value, but C&R is appropriately defined as the disclosed hud1 fee. It’s somewhat complex and muddied though, even the direct orders also do carry a somewhat higher fee for consumers. Direct often does rake a small set fee. Where is the legal line? I trust Mr Miller will continue to advocate for sound valuation practice.

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    • Chris says:

      I vote for you to be put in charge !!!

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      • Baggins Baggins says:

        Me? No, you don’t want me in charge of real estate. Some sweeping policy changes, to 80% max ltv, audit the fed, increase to 700 score & eliminate cc requirements because proving you have risky credit is a poor criteria, eliminate fdic insurance in flood areas and make them pay special risk assessment fees instead, limit gse lending to 15yr or shorter terms and move the rest to private hard money, well, I’d kill more deals in one pen swoop than any appraiser in history.

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        • Baggs, I remember the days of 10% down payments and 10% seller carried second TDs. The reason for them was simple.

          Far more people wanted to sell houses than those that wanted to buy them AND had 20% plus (then) 3% closing costs. ONLY alternatives then were VA or FHA and seller paying typically 3% in points.

          Initially sellers would say “If they can’t afford 20% down, then I wont sell to them!”. Then when sellers decided they REALLY wanted to sell rather than merely list for sale, they’d get realistic. Less than 5% to 10% of potential buyers had cash DP. If you wanted the other 90% you either had to take a second TD back, or pay points for VA/FHA financing.

          After 1972 “ish” 5% and 10% DP with  no secondary financing insured loans popped up (and disappeared overy few months) until the PMI companies lost more than planned.

          We all have to remember that its hard to put the Genie back in the bottle once it/he is out. Effective Demand still drives the R.E. market…not simply demand for new housing like the media would have us all believe.

          Demand, absent ability is not demand at all.

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          • Baggins Baggins says:

            Wow, great history lesson. Quite right very astute about demand. And inflation carries onward, more dollars these days for the same silver quarter. We’re not experiencing home appreciation, we’re experiencing inflation. A consequence of the political gridlock imposed on more sensible approaches like maintaining more consistent currency valuation and allowing for the market to self correct through more responsible terms and long term corrections based on consistent policy. The beat skips on.

            Seinfeld; [on stage] “What’s the deal with political advocacy on behalf of vested interests in real estate, I mean like what about the buyers?” (from audience; ) “That’s what she said!” (audience laughs, Jerry points at the heckler, smiles, and bows). [curtains].

            In other news, most disagree with me that manual is better, oh well, I’m stuck in my ways and like it that way.

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  13. Sound economic policy and politics have rarely gone hand in hand. The odd thing is that budgeting is really easy.. “X” dollars coming in; no more than “X” dollars going out.

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AMC Fees Exceeding Appraiser’s Fee

by Jonathan Miller time to read: 1 min
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