Day Laborers Needed…Inquire at any AMC
Help Wanted – Day Laborers Needed …. Inquire at any AMC
The Dodd Frank act requires the lender to be responsible for their agents. This means the lender is responsible for the actions of the AMC. Do the lenders know what their AMC’S are doing? Probably not.
The Dodd Frank act also requires the most qualified appraiser be selected for each and every assignment. What vetting is done by the AMC’S to ensure the most qualified Appraiser is selected? Many AMC’S have the false mentality every appraiser is qualified and competent to appraise every piece of real estate. This simply is not a sound theory. Just because an appraiser is licensed to appraise a certain type of property, that does not make them qualified, nor competent for each piece of real estate. If an appraiser accepts an assignment in which they are not qualified to complete, the appraiser has certain duties to the client under USPAP; all with the intent to protect public trust. The purpose of the Dodd Frank Act was also to protect the public trust.
Many AMC’s just don’t get it. They force appraisers to respond to emails, and now text alerts with the mentality of the first to respond gets the order, often at well below customary and reasonable fees. How often are such an requests made after normal business hours?
This business model reduces appraisers to the equivalency of day laborers standing on the corner waiting for a truck to come by and pick one person for a day’s work. This practice is viewed by many State and Federal agencies as non- compliance with Dodd-Frank and harms the consumer. How many other Licensees from the Virginia Department of Professional Occupational Regulation are subjected to this environment?
State coalitions are working relentlessly to overcome and change how AMC ‘s conduct business and treat professional appraisers. Here in Virginia, VaCAP continues to preserve and promote the appraisal profession, and citizens of Virginia through education and legislative change.
Help VaCAP promote and preserve our profession. JOIN VaCAP TODAY and make a difference.
Customary and Reasonable Fees in Virginia
The Virginia Real Estate Appraisal Board held it’s quarterly meeting on November 17th. Customary and reasonable fees was the bulk of the discussion. A committee was formed to research the best way to determine customary and reasonable fees in Virginia. Rumor has it there will be a public comment period in January. VaCAP will let you know more as this information is released. If you support customary and reasonable fees in Virginia, join with VaCAP to preserve and promote the appraisal profession.
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well, well, well. i have to say that i am getting somewhat impressed!
could it be that people are finally understanding what appraisers have been saying for a VERY LONG TIME, a MILLION TIMES, over MANY YEARS, about fees and all the other garbage that has been going on??
maybe it has to do with the ridiculous number of appraisers that keep calling it quits every year/renewal because it just isnt worth staying in business any more, that has people finally paying attention?
could it be that banks are starting to experience problems with how quickly loans are being processed because it takes so long to do one appraisal nowadays?
could it be that after the new handbook came out, a large number of appraisers stopped doing FHA work just like they said they would?
could it be that banks are starting to have a hard time finding appraisers to do rural appraisals because low fees just dont make appraising those types properties worth it any more?
could it be that although there may not be a shortage (in numbers) of appraisers as some people predict, (and i dont agree with), an ever-increasing number of appraisers refuse to do mortgage work anymore because of low fees and ridiculous liability, and are instead doing other types of appraisals? (something i do agree with).
something tells me that we are now in that major crisis mode just as appraisers predicted a long time ago, and the system is finally starting to experience it. all of a sudden there is a lot of talk about fees, AMC’s, and changing the ridiculous education requirements, isnt there?
we are now starting to find ourselves in a VERY BAD storm . . . . .
maybe its about time that the system strongly considers letting REAL APPRAISERS who actually do the work every day and have their boots in the streets, start making the decisions around here, instead of the clueless people who do nothing but wear suits to office and sit behind desks in air conditioned offices for 40 hours a week.
its a glimmer of hope, but unfortunately because of all the very poor decisions that created this whole mess, a tremendous amount of damage has already been done, and its way too late for a lot of appraisers and the system now.
the bleeding continues . . . . .
Hmmm. day workers. that’s an improvement over the phrase i think fits us better, welcome to the plantation. enjoyed the article.
Here is the “fast and dirty” way to determine whether an appraiser is competent to appraise a property:
Does the appraiser accept AMC assignments for less than $500?
(If they answer is “YES” the appraiser is not competent).
The logic behind this argument: The appraiser doesn’t even have the intelligence to place an adequate value on their own tiime; why would you trust them to value real estate for a lender?
Timely article.
I think the first question is whether banks even CARE whether AMCs are doing what they are supposed to be doing, as long as banks can maintain the pretense of plausible deniability. Easy answer- No. They do not. As long as we continue to have insured loans backed by taxpayers for commercial enterprises corporate profit they have no reason to care.
If the average CEO’s corporate life expectancy is three to five years; he or she is ONLY concerned with maximizing quarterly profits and his or her own executive compensation package. They are gambling that if or when the house of cards collapses every 15 to 20 years, that they will already be long gone; and even in the case of subsequent federal inquiries that they have ‘legal cover’ and as noted above; “plausible deniability.”
As for AMC vetting of appraisers, the first criteria is willingness to work for lower than reasonable fees. ALL AMCs adequately ‘vet’ for this requirement. The second element of their vetting may be willingness to not only work for lower than reasonable fees, but also to be willing to pay for the privilege! Pay for client-specific background checks; specific levels of E&O insurance naming the AMC as a co insured or other insured/indemnified party, payment of upload fees on a per report basis, and in some cases AMC set up fees.
Once the appraiser has passed each of the above stringent ‘vetting requirements’ they are usually welcomed into the fold. Many AMCs also have a further requirement that the appraiser is certified, so that they may ASSUME he or she is qualified to do anything they throw at them with out additional inquiry; even though all of us know that is not the case. I know many certified residential appraisers that simply do not want to do 2-4 unit work-though their license says they can. Same with acreage or complex work. The specific ‘assignment vetting’ is typically “Can you do this assignment, and for how much and how long?”
To an AMC there are no normal business hours! It’s 4:25 on a Friday afternoon and the clerk has just hit the send button on their email for a $350 fee complex assignment they want completed by Wednesday or Thursday. It WILL require a fee adjustment, but no one knows that yet because no one checked to see if it was a factor! In the mind of the AMC the appraiser has Friday, Saturday, Sunday, Monday, Tuesday and even into Wednesday to complete and deliver the assignment. What’s the problem, right? I mean six days should be enough for anyone, correct?
I don’t know abut you, but I only work weekends for significant premiums OR because I choose to-not because some AMC sent me an order 5 minutes before I’m done for the day.
VaCap is right though in their analogies. Further SOME state coalitions ARE very actively working to try to overcome how AMCs conduct business. VaCap, North Carolina, Louisiana, possibly Texas and Illinois; and even California are trying to effect change. EACH state however has different interpretations of how Dodd-Frank is to be enforced, OR whether they can enforce it’s provisions at all (California does not) I urge ALL to support their individual state coalitions in dealing with state regulated AMCs.
Having said that, the real problem and challenge is at the federal level though. THAT is where the banks plausible deniability that leads to poor AMC policies originate. Virginia is one of fifty states. While we can and will point to their sincerely hoped for successes, their actions will not directly affect the larger national issues arising from non uniform state AMC regulation, and variable selective enforcement of Dodd-Frank.
Only national organizations can do that. That is why I urge all to join the AGA janbellas@appraisersguild.org or (301) 220-4100. It is why I am trying to build a bridge between appraisers and the National Association of Realtors (NAR) -Don’t scoff. Some modest progress has been made. CAR & NAR asked for help recently with the Senate and House Transportation Bill to insure mortgage add on fees as a tax for borrowers only (G-fees), were not added into the bill. Both House Member Alan Lowenthal and Senator Diane Feinstein (from my state) responded favorably and the bill is now in conference where it is hoped they will continue to keep the House version.
Folks THAT is what we have to do to effect changes! NAR has the biggest lobby in the country. We need to add the voice of AGA which is not insignificant; NAR which is huge, EACH individual state coalition (which are varied), PLUS a more effective national coalition (seems to effectively exist as a concept only), to the existing appraiser peer groups so that we have ONE HUGE UNIFIED voice seeking redress, rather than disparate smaller voices…that few listen to.
It starts with you. Invest in your profession.
In other news…It seems Illinois had over 943 appraisers that did NOT renew this year. For those willing to gamble, in another five years MAYBE things will fix themselves, right? I mean banks; FNMA and Wall Street wouldn’t try to circumvent appraisals altogether, would they? WOULD they?
Yep, that’s one of my primary arguments against broadcasting and fee quoting and such. I ask the amc worker, if they will be working tomorrow, or if they have to be the first to respond, to have the honor of a steady paycheck. As amc staff is largely telecom, and telecom turn over is traditionally higher than other industries, it’s quite likely they’ll never get it. Broadcast and fee quotes carry a hundred dollar automatic surcharge for both the wasted time and effort because so many companies do that, as well as the difficulty with scheduling and the need to maintain a much larger client roster. Gone fishing.
I think it is great that VaCap, as well as union members, AI, NAIFA, ASA, IRWA, and on and on and on…..voice their opinion as to the improvement of the appraisal occupation. There must be 30 to 40 separate organizations collecting dues from our group in an effort to promote our occupation. They are damn good at collecting dues and selling educational courses. Not so good at doing anything to promote our “pitiful profession”. Maybe we need a few more newsletters? Maybe we need a few more nitwits advising “us” as to how an appraisal should be prepared?
Just think…FNMA stock is at the nosebleed HIGH of $2.10 at close today. REALLY? TWO damn dollars and ten cents a share and that is with the United Stated Federal Government supporting them to the hilt! FNMA is suppose to be so smart…they know it all and tell appraisers when to jump and how high. Are you impressed? I know that I am!
As we know, this occupation has some serious problems. We really need ONE organization that will represent our combined interests. A group that can treat all of us in a fair manor and as equals. THIS GROUP IS NOT THE APPRAISAL INSTITUTE! They have had their chance and have proved over and over that they do not represent anything but the special interests of their upper echelon group. No need to go there!
I think we all know by now that there is no one riding the white horse being the champion for our cause. We are a very loose group of independent thinking folks that are going to do it our way. So many of us are too old to change professions. We have no choice except to try to hang on until retirement, whatever that will bring!
I am one of the old folks. I will hang on for a while and enjoy watching the AMCs go out of business because they are unable to find appraisers who will work for them. If I were asked to make a recommendation to our group I would simply say that the young people should move into another profession. The old folks like me should hang in there until retirement. There does not seem to be any extended future in this occupation. This is a game of parasites and hosts….the parasites have won!