AMC’s “My Way or the Highway” Attitude

Michael Ford

Michael Ford

General Certified Real Estate Appraiser at Michael F. Ford Appraisal
Over 28 years appraising all property types and interests, in Southern California real estate. VP/Chairman National Appraiser Peer Review Committee, American Guild of Appraisers, #44OPEIU/AFL-CIO. - Michael Ford on e-AppraisersDirectory
Michael Ford

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AMC's “My Way or the Highway” Attitude

Apparent appraiser abuse by AMC’s…

As Chairman of the American Guild of Appraisers (AGA) National Appraiser Peer Review Committee, I have had the opportunity to see and hear directly about many cases involving alleged, as well as apparent appraiser abuse by AMC’s. These cases ranged geographically from California, Arizona, Michigan, Illinois, Florida, North Carolina, Louisiana, New Jersey, Virginia, New York, Maryland, and District of Columbia.

As a QC consultant to a smaller appraiser owned AMC, I have also seen low fee spreadsheets from a variety of lenders that had 90% listed at the SAME APPRAISER fees: $495.00 (which INCLUDED the AMC cut) ranging to a high of $550.00. In most cases the AMC were reported to be averaging between $150 to $200 per non complex, FNMA  conforming loan limit transactions. Some were reported as being as high as 50% of the quoted fees.

While the (generic) lender clients TALK a good game about appraisals being USPAP compliant, that frequently only lasts until THEIR deal is jeopardized by a purported “low” appraisal. This typically triggers a request for reconsideration (usually without new data), followed by a request for a desk review if the reconsideration fails.

The desk review is not intended to determine overall appraisal credibility. It is usually sought only if it already appears a technical oversight has been identified in one or more areas. THEN that appraisal review is used to justify ordering a new appraisal (appraiser shopping was the client intent all along) OR to exert Collateral Underwriter (CU) rating pressure. IF the new appraisal is higher, then the original appraisal that may have had no significant error, is turned over to the state board by the client/lender so that the illusion or pretense about quality control can be maintained; as they in turn create their own internal defense file against any possible future claims of appraisal shopping.

Oddly enough, the same thing is almost never seen where the appraisal is (allegedly) 5% to 10% HIGH.

Anywhere in the process after the request for reconsideration fails to achieve desired goals, the lender to AMC account rep will file THEIR inevitable complaint about the (1) AMC picking bad appraisers that are killing deals, or (2) specific appraisers killing deals.

Rather than less improper pressure being brought to bear on appraisers, there is more. Where before they risked only losing one client for upholding ethical standards, now they risk losing their livelihood if only one or two large AMC’s control all the work in their state or county.

As an AMC QC consultant I also routinely see the detrimental effects of low fees on basic appraisal quality. As fees come closer to being ‘reasonable’ there is a corresponding decline in the volume of bad appraisal work. Clearly, time and adequate compensation remain quality control issues despite Dodd-Frank.

The obvious solution for AMC’s is cost plus pricing. I suspect some, if not many or even most resist this because it precludes them from collecting the higher 50% fees from naïve or financially desperate appraisers. Some banks may also resist it because they now see appraisals as separate ‘profit centers’ where traditional ‘junk fees’ can be assessed even where there is no lender appraisal related overhead.

There should not be an unregulated or unlicensed AMC in America today. Their ‘banking’ clients are regulated and so are their appraiser vendors. Why would the intermediaries or “independence firewalls” be left unregulated?The larger AMC’s cite smaller ones as being the rogues and uncontrolled entities promoting bad habits, but my experience demonstrates just the opposite. Eighty to ninety+/- percent of the cases I’ve had put before me for review have involved very large lender owned AMC’s, or “Independent” national scope services. Smaller AMC’s can be problematic but generally lack the ‘our way or the highway’ arrogance of the larger ones.

Rather than to seek better ways of assuring compliance, those big enough to have the deep pockets to hire lobbyists seek to have the regulatory rules and laws modified to suit THEIR needs.

This will without the tiniest doubt lead American taxpayers back into the conditions that brought us to TARP I and TARP Two; It will lead to another economic collapse which will not be as relatively assured of being ‘curable’ because confidence of the American buyers and sellers will have been destroyed permanently.

Both American consumers and taxpayers can only be lied to so long before they react in the only way left to them. Withholding their check books. We’ll see long term artificial constraints on value similar to the  instability of the short sale markets of 2009-2011.

Had FIRREA of 1989 been followed instead of being gutted, twisted and reinterpreted right alongside with USPAP every two years to suit lenders, the collapse of 2006-07 that culminated in November 2008 never would or could have happened.

Rules and laws are passed for reasons. The discussion should not be about whether to enforce them. It should be about why they have not already been enforced. A question that arises more and more in America of 2015.

There should not be an unregulated or unlicensed AMC in America today. Their ‘banking’ clients are regulated and so are their appraiser vendors. Why would the intermediaries or “independence firewalls”  be left unregulated?

The ONLY reason for an AMC to be unlicensed today is if a particular state does not yet have a license law. To their shame there can only be one reason why they have no such laws. Their leaders LIKE the disorder.

If there is an AMC practicing without a license in a state that requires one, then that AMC has already proven that they cannot be relied upon to follow laws or regulations. Why would we think that voluntary or perceptual things like ambiguous ethics and integrity would not also be ignored, or at least parsed so carefully as to be meaningless?

The entire United States waits for Virginia to do the right thing. I hope it is not in vain.

Photo Credit flickr - Dan Taylor
Michael Ford

Michael Ford

Over 28 years appraising all property types and interests, in Southern California real estate. VP/Chairman National Appraiser Peer Review Committee, American Guild of Appraisers, #44OPEIU/AFL-CIO. - Michael Ford on e-AppraisersDirectory

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47 Responses

  1. bubba jay bubba jay says:

    an appraiser friend of mine has been dealing with an AMC over the last week or more about a report she did. clearly, some reviewer at the AMC wants parts of the report done their way, and i feel my friend has been accommodating with some of their requests. however, the AMC is now telling my friend that unless the rest of the report is also changed exactly the way the want it, they will re-assign the report and not pay her anything for all the time she has spent on the report.

    Mike, please be sure to add “extortion” to our work creep list too. thank you.

    the bleeding continues . . . . .  

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    • Koma says:

      Bubba, she needs to drop them like a hot potato! There are so many more clients out there, well at least in my area. Had a client try that with me, dropped them, the next day a supervisor called listened to what I had to say and now we are good to go.

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    • Retired Appraiser Retired Appraiser says:

      If the changes the AMC are requesting impact the final value conclusion in any way (especially different comps) let the AMC know that they will be reported to the appropriate officials for attempting to coerce the appraiser into altering the final value.

      Been There Done That…and I was paid within 3 days.

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  2. John Moonitz says:

    Blah Blah Blah Blah Blah!

    I agree with almost everything you have said here . . . just as I have agreed with most of what many others have said in similar posts and articles  . . . I have been agreeing for many years now . . . Those who are supposed to represent our industry talk and talk and talk . . . BUT NOTHING GETS DONE!!  While it feels great knowing that there are others who understand our plight, this does nothing to improve our industry!

    We appraisers have ourselves to blame . . . we could have organized in each respective state, and without price fixing, without naming a base fee, we could have simply agreed, in California, for instance, for a two month period of time, to not accept a single order that didn’t have a fair and reasonable fee for the appraiser (in CA that is now between $400 and $450 per SFR/Condo and $700 and $750+ for multi-units) . . . again . . .  these fees would be understood .. . and the lowest any appraiser should be willing to accept is $350. If we were to do this, the AMCs and any other institutions would have no choice but to start paying the reasonable fees! We aren’t grocery clerks . . .  the banks and AMCs can’t hire scabs to take our place while we refuse to accept substandard fees! We have all this power . .  . and too few are willing to use it! Nobody with any influence will attempt to organize the appraiser’s in California, or in almost any state . . .  Maybe because those appointed to protect this industry are wealthy enough and connected enough that for them to actually DO THEIR JOB would be detrimental to their easy lifestyle.

    Well . . . shame on them and shame on us!  This industry is ruined . . . utterly and completely ruined. The new appraisers coming in bolster up this garbage industry as it is, accepting crappy fees, taking little or no pride in their work (how could they?? When all is said and done, they are making less than they would as a server in a moderately busy Denny’s!!).

    I’ll say this in closing . . . our economy is collapsing . . . and we are partly to blame . . . not for what we have been accused of . . . but for allowing these Cretans to destroy our industry. Our blame in the total collapse of our economy, and soon after, what is left of our Constitutional Republic, is minimal . . . but this does not change the fact that this collapse is coming .  . and I’m ashamed that my industry as a whole, it’s so called “leaders” in particular, just laid down and died without a fight. Pathetic.

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    • John, you are right. By the way, California DID form a coalition (CCAP or if you prefer CaCAP). Headed by George St Johns, along with original co founder Rey Cano of Malibu Appraisal. If you are not already on Rey Cano’s email list, you should contact him and get on it. His specialty is saving appraisers money on courses (like free AI courses); and other helpful time and money savers. He does it because he cares-not because he is making any money off it.

      I recently worked with George on behalf of the AGA in trying to get AB624 suppressed in California. While George met with the bill’s author (whom he knew personally), I spoke before The Appraisal Foundation, ASB in Redondo Beach; along with many others opposed to the bill. The ASA carried a letter from us to the State Senate Finance Committee meeting for the next week that I could not go to. We ARE working

      We spoke in opposition to the AI which is trying to get the bill through so that THEY can use THEIR standards instead of USPAP. Their new standards allow for contingent fees; which for years THEY have been telling us, is a major no-no! We hope to be able to join WITH the AI on other issues in the future rather than against them, but in this one we simply disagreed with the process that was used to move the bill along.

      John, its been said before, getting appraisers to do ANYTHING together is like herding cats. Part of the problem is that ‘we’ like to write and vent, but not actually have to DO anything. Right now there are 19 to 21 active state coalitions in America. ALL need more members to be more effective. By themselves they have had some notable successes IN THEIR STATES, but had almost no impact nationally.

      THAT is where the Appraisers Guild comes in. We CAN effect national changes-not because we are ‘special’ or so brilliant, but because we can bring the full weight of the OPEIU / AFL-CIO to the table where hopefully our issues will be heard favorably based on their own merit.

      We too need more AGA members. I need at least 100 more in California just to be able to keep up with membership drives; monitoring upcoming issues, dealing effectively with existing ones, blogging, position development, research, education, Congressional outreach & advocacy, media outreach/ PR, and my particular favorite-defending other appraisers from unfair treatment from ANY sources-whether it is their states regulatory officials; AMCs, lenders, or GSEs.

      It may surprise you but I am engaged in at least one new case per week.

      Yes John, just a ONE MONTH AMC ‘vacation’ by ALL of us would temporarily ‘fix’ low fees. Until the next scheme is hatched by AMCs and lenders to suppress appraisers. I want more permanent fixes.

      I’m trying to ‘herd all the cats’ into a unified position right now. A really simple one. Joining the AGA so we can DO something, as suggested. Some are joining the group-others are doing what cats do…whatever they want.

      Contact janbeallas@appraisersguild.org

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  3. Bill Johnson says:

    Although I understand the article is about AMC’s and their policies, I think the pressures are just as great from the lenders themselves. My current issue is with a lender that does not like my response as it relates to a legal nonconforming property. The minimum lot size is 5,000 sf and the property sits on a 3,500 sf lot. They want me to make a statement that the property can be rebuilt if destroyed, however in speaking with the city, without a formal Zoning History Letter, no such guarantee can be 100% certain. The underwriter does not appear to have an issue with my comments and requirements (obtain the letter), however the internally ran preferred appraisal panel manager does. As the panel manager, she is the gatekeeper for the unhappy loan officers and agents and has contacted me directly to request the change. The cost to obtain the letter is $500 and more importantly the wait time from the city is 3 weeks, or past the rate lock time. I can hold my ground (tell them to get me the document) and do the correct thing, but most likely get kicked off the appraisal panel, or I can give into the pressure and provide a rebuild statement without confirmation from the city. This non AMC client pays a fair wage and accounts for over 20% of my yearly income. Lenders and AMC’s don’t want the truth, don’t care about USPAP, don’t care about appraiser liability and don’t care about the appraiser.    

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    • Bill, depends on your state. Another option may be to provide them with a copy of the city code concerning rebuilding. Many say if the property is not more than 75% destroyed, (or other variants) that it can be rebuilt and the non conformity may or may not be increased by no more than 10%. Based on that an extraordinary assumption is made that the subject could be rebuilt based on the cities published code concerning non conformities. You can argue or parse that the foundation is 25% and destruction of more than 75% is unlikely. Don’t violate your principles, but DO reconsider whether you can give them something to keep a client that you don’t want to lose without crossing the ethics / integrity line.

      Separate possibility. (Again applies in California) maybe not in your state. Minimum lot size refers to new subdivision. Under California law a City may NOT refuse to allow development on a legally subdivided existing sub standard sized site as long as other site development requirements for similar sized sites can be met. I offer these two possibilities only because you said this is a good client that you want to keep.

      As for spending $500 or even $50. out of my own pocket to get them their rebuild letter, that is simply not in the scope of my contracted services-ever. They can have the property owner go down and obtain the rebuild letter just like Id have them do for permits or a C of O. Not my job.

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  4. Retired Appraiser Retired Appraiser says:

    I recommend THE HIGHWAY to appraisers.  AMCs are doing you a favor by encouraging you to throw your business in the trash bin.  Let the AMCs fill these miserable liability filled orders themselves and see how long it takes for them to go bankrupt.

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  5. Retired Appraiser Retired Appraiser says:

    Mike

    If the AGA ever becomes the advocate for boycotting AMCs en masse let me know.  I haven’t touched an appraisal for six years but I will contribute handsomely to any group of significant size that will sponsor such a counter attack.  I suspect that thousands of appraisers and ex appraisers would contribute $200 to $1000 to anyone with the balls to sponsor such an attack.

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    • RA, I keep trying to tell appraisers we are NOT your grandpa’s old style union. That means trying very hard to work in cooperative ways wherever possible; or in the case of AB624 though our labor relations reps *g* who just may have spiked the bill.

      Is a strike or boycott possible? Only in theory as of today. Tomorrow?

      Maybe. We are advocates of what will work within our existing means. In the Dingeman case involving Chase, I understand OPEIU or AFL-CIO actually went so far as to withdraw the pension funds from their trust accounts there and put them elsewhere.

      AMCs are here to stay unless and until such time as it becomes MORE costly for banks to do business through an AMC that it is to administer their own appraisal departments like they used to. The trend is the other way. I MA Y have mentioned this. I am  PRO business, free enterprise, level playing field advocating Republican union organizer. I don’t think ‘strike’ right out of the box.

      I look for win-win solutions. If none are found after sincerely reasonable efforts are exhausted, then I am more than willing to go nuclear and to urge my parent unions to support that position.

      So far they haven’t tossed me out, even after I was critical of OPEIU’s President’s Annual message letter to the membership. In fact, its been just the opposite. Our support from OPEIU under Mr. Goodwin has been outstanding.

      RA IF the time comes to call for a national boycott, I assure you that a self identified Republican union organizer; former Marine has the balls to do so. Right now, it would be a call in an empty room. Who would heed it? You getting any closer to joining us yet? We could use you.

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      • Retired Appraiser Retired Appraiser says:

        Mike

        I’m not speaking of a strike but rather a boycott of AMCs.  If you can come up with 500+ appraisers who are willing to participate it will snowball from there.  Once you hit a couple of thousand you have a story that the national news cannot ignore.  After that you’ll have every appraiser that’s been in the business for over five years begging to join.  It’s been feasible from day 1.  I had a list of 50 who were willing to do so 4 years ago but it never took hold.  Appraisers have been raped so much more since 2010 that it’s unbelievable.

        If the AGA builds it…they will come.  Quite honestly it is the ONLY approach that has a chance of giving power back to the appraiser in our lifetimes.  People are simply unwilling to discuss the option.

        Remember the 1981 Air Traffic Controller strike?  They relied on military air traffic controllers to break the strike.  How many residential appraisers are in the military?  Zero

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      • Retired Appraiser Retired Appraiser says:

        Mike

        This was the original AMC petition that I threw together in a jiffy around 2010.

        It gained over 100 names within a couple of days but Change.org quickly showed that their site was unreliable. It was down far more often that it was active over the following month.

        I then created a professional website, promoted the idea of producing a documentary to let homeowners know just how much they were being screwed by HVCC. The working title of the documentary was Bank Raped. Amazingly I also found appraisers willing to contribute funds for the production of the movie but we fell short of the amount needed. In the end we pulled the plug on the project and refunded everyone’s money.

        I recommend that the AGA do a small poll among appraisers. What course of action would produce the most immediate results with regard to restoring control of the industry to appraisers and raising fees? Include a boycott of AMCs as one of the multiple choice answers. Ask how many would be willing to participate in an AMC boycott in order to raise national awareness and get the story on the national news?

        A poll costs you nothing. You may be amazed by the results.

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        • I am forwarding this to our Guild President. You offer several good ideas. I am especially grateful that you and others took the time to offer suggestions.

          One item I noted in your original petition was a return to the old “Field Collect” at the door that used to be customary. FNMAs official policy is that they will not accept any appraisal where the fee has been collected by the appraiser directly from the homeowner or borrower. So even if we had such a boycott, that objective would not be achieved unless we are also going to take on FNMA. They, I suspect would love to have an excuse to use AVMs. Legislation already exists whereby they are not required to even have appraisals for transaction amounts under $250,000. If they could say “gosh appraisers are on strike, so we need emergency authorization to buy loans without appraisals” I bet they’d be happy to do it.

          When you wrote your petition article up in 2010, I’m guessing we still had over 150,000 appraisers in America. What do we have now? 85,000±?

          ALL of your other ideas are excellent and among what we already consider top priorities (actually my OWN goal was also to get back to us collecting our own fees, but I think there is a better way to approach that now; perhaps payment accompanies order within three days of acceptance. If payment is not made, the inspection is not even set up-so we minimize lost labor by cancellations).

          I’m all for a two part poll asking what appraisers want, and how they feel we should go about achieving it (existing appraiser groups like AI or ASA?; state coalitions; national coalitions; appraisers guild or all of the above? ) Followed up with information on how to join AGA. (OK, I’m biased but the best idea in the world dies of loneliness if we do not have some way to marry it up with an effective vehicle to promote it).

          I also think that IF we can get the State Coalitions to get behind us, AND / or grow our own numbers large enough that we can get an entire rewrite of FIRREA Chapter 11 pushed through fixing ALL our complaints in one single legislative effort, why waste ANOTHER five or ten years on single issues like AMC licensing, then C&R fees, THEN timely payment, then blacklisting, etc if we can get it ALL done at one time? Five years from now I just want to be ‘monitoring’ complaints to insure members are fairly treated. I’m hoping we won’t still be fighting for the BASIC needs your poll and our members have already identified.

          Somewhere in there I need to get MY guild and union sponsors to approach MY political party with an olive branch. Not to capitulate on labor issues, but to let them know that the DNC cannot count on blind labor support anymore. They’ve pretty much sold out to government employee unions anyway already. Frankly labor unions of today have more in common with American ‘big’ business than they do with the DNC’s schizophrenic causes that range from everything EXCEPT job creation. It is just that they have been going steady with the DNC for so long, I don’t think they ever considered an alternative.

          The reason I say that, is it is very probable that both houses of Congress and the Presidency will move more toward business creation in the next couple years. My idea isn’t as far-fetched as it sounds. Mike Goodwin’s (OPEIU) own annual message to membership indicated that traditional recipients needed to be put on notice that contributions may dry up for failing to support job building legislation; and to oppose job killing legislation. I’m not trying to turn this into political views, but we have to recognize the realities we operate under. Right now we can use labor strength. In two more years that may become more difficult. Maybe it’s time for ALL non-government unions to start looking the most basic need of labor – a good job with some reasonable probability of stable employment!

          The Government labor unions are seriously hurting the image of ALL labor organizations with the crap they are pulling like the no tell retaliatory warrants in Wisconsin; and a host of other actions tied to them across the country. They epitomize the arguments I encounter from people that WANT to organize, but think all unions are either socialists, anarchists, and just plain anti-business, lazy loonies looking for a free ride.

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    • Mike Ford Mike Ford says:

      RA, IF we ever are forced to do that I have no doubt leadership would support it, BUT you have to remember (1) Appraisers are anti-union; anti strike as a rule. So the support we gain on one side, is offset by losses on the other. (2) I keep telling people we do things differently than traditional unions. We actually all work VERY hard to make the changes we need, BEFORE going nuclear. (besides, we BOTH know that red lines drawn in the sand without meaningful follow up are worse than useless).

      500 appraisers unenforceably “pledged” to a boycott is not as threatening to AMCs as it sounds. On average, that’s only ten per state. 5,000? Maybe, but in my state I think we still have almost 10,000 or at least 7,500 licensed/certified appraisers on board. Would 100 missing for a day make a difference? Doubtful. For a week? No, that would just make the rest that get the overflow work happier. Respectfully RA, I think we’d have to be able to convince at least 25,000 to boycott. Now 500 members in our California Chapter, THAT could get some support and publicity. Heck I used to routinely get local newspaper support and even L.A. Times coverage with a group that was only 50 strong in a City of 150,000.

      Give me 25,000 AGA members, and I’ll make AMCs PAY US for the privilege of representing us! OK, maybe not that far, but you get the idea. If we can get enough people to pull off a single day boycott, then we should be able to get enough to COMPLETELY CHANGE ALL THE LAWS that are used to abuse us in which case a boycott becomes unnecessary.

      Come ON R.A., I KNOW you are one of those old time semi wealthy appraisers that squirreled away lots of acorns. Join us at AGA and HELP us win the entire war, not just a battle. I seriously need help from more people (like you) with an understanding of what needs to be done. You fit that bill. Come on, now that you are retired, you need some kind of tax write off anyway. Union dues are deductible! (so you become a professional appraisal consultant and stay retired). Why with the money you’d save from dues deductions alone, you could go out and buy a whole tank of gas! (unless you drive a suburban or something).

      Send Jan an email and join RA; janbellas@appraisersguild.org

      Best,
      Mike

      PS You don’t really want any of us flying people around for Piedmont Airways anyway, do you? My eyesight alone is like 20/200 or something equally dangerous for flying.

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      • Retired Appraiser Retired Appraiser says:

        Mike

        I wasn’t suggesting that appraisers become air traffic controllers. I brought up the air traffic controller strike to illustrate that IF appraisers were to boycott AMCs there would be no way to bust it since there are no residential appraisers in the military to screw things up for us.

        I did contact Jan with my idea. I essentially told him or her that appraisers and appraisal groups have had 6+ years to throw about pretty words and exchange eloquent letters. Appraisers are in far worse shape now than they were in 2009. Words are cheap Mike. Taking back one’s profession requires a real cause (an AMC boycott), real effort (on the part of appraisers), and real leadership (something that no appraiser group has demonstrated to date…especially the Appraisal Institute).

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  6. Desiree Mehbod Desiree Mehbod says:

    I just received this information from a VaCAP member:

    “There are currently 129 AMC applications. 95 have been approved as of 8/18/2015. 34 are still pending and are allowed to operate until 12/31/2015.

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  7. Mike Ford Mike Ford says:

    Interesting re pending applications. I assume VA had no AMC previous license requirement?

    The more I do research on Coeste’rs history in Virginia as well as other  states, I have to wonder how they are allowed to continue anywhere.

    If ANY appraiser had that many sustained complaints or consent agreements they’d never get another appraisal license period.

    IF the ad on their own webpage is correct, then these are the folks that brought the Unreasonable fee to banks from AMCs of $450 to it’s current flat rate of $495.

    If Louisiana already found that SAME FLAT RATE to be unreasonable and unsupported, it seems like it should be unreasonable in each of the states that they operate in. Appraisers cannot reasonably expect to get MORE than the fees the banks have already agreed to pay AMCs, so maybe the calls for a boycott ARE needed.

    That and a federal investigation into price fixing by non appraisers.

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  8. Bill Johnson says:

    Although much of the talk in this industry is about the appraiser to AMC relationship, I see a big trend (elephant in the room) that know one is addressing. Most of my clients now go through SAAS companies (software as a service) that don’t need to be identified as such in the appraisal. These hybrid type companies seem to offer  many service options to the lenders, but apparently do not cross the line to call themselves AMC’s. The relationship between these SAAS companies and lenders to my knowledge is completely unregulated, however its very similar to a lender to AMC partnership. Simply put, the borrower pays what shows up as an appraisal fee, the lender pays the SAAS company a portion of that fee, and the appraiser ultimately gets a split. Although we can boycott what would show up in our reports as an AMC client, the lenders have already found a way around the regulations. Big government takes years to propose, approve, implement, and enforce, but the profit centers at these banks can alter the rules of the game in a matter of days.

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    • Bill, they sure sound like they’d fit most definitions of an AMC if they are the ones you have to sign up with or get paid by; OR if they have any decision making as to who gets an assignment.

      Have you got a link to any of these services? I’m curious as to who is doing the banks due diligence to assure USPAP compliance as federal law requires them to do?

      You’re right though, this bears a LOT more looking into. Who makes the decision about fee increases; or responds to requests for more information-like copies of CC&Rs, or missing pages of the contract? When you pick up the phone because appraisal conditions warrant notifying the client of some necessary change, who do you call? Bank of SAAS? Can you call anyone or is it all via proprietary system email?

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      • Bill Johnson says:

        Mike, I’ve seen this issue from both sides of the isle. A strictly SAAS company will at a future time also start up a separate full service AMC division and where a full service AMC company spawns off a separate SAAS division. As an example, Streetlinks (an AMC) has a separate platform they call LenderX, In-house Solutions (an AMC) has what they call a Connexions system, and Solidifi (an AMC) has a platform they call Smartflex. In most cases, the appraiser is informed to indicate No AMC in the report versus using the sister company/traditional label of the ordering AMC. In discussing the business model with these AMC’s the point of these hybrid options is to give the lenders who want to keep their own panel of appraisers, a managing partner. The lenders do not pay a full service AMC management fee, but rather the appraiser will pay according to what options they want from the software. I don’t begin to understand what constitutes an AMC designation, but an option often given to lenders revolves around appraisal assignment. I have been told for instance that lenders can work from a simple rotation system, proximity, proximity with score rating, etc. Although in my previous post I noted a similar split fee policy for these SAAS companies, my experience is that the fees ultimately paid by the appraiser, are in the $25 to $75 range, versus the much higher AMC fees. Although I don’t claim understand these new systems fully, there is an undeniable benefit in higher fees to the appraiser. The point of my previous post was to indicate that our fees are not just being split with known AMC’s (as disclosed in the report), but rather even when I have success and get work via a SAAS company (No AMC in the report), a portion of the appraisal fee is still being split.

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  9. bubba jay bubba jay says:

    i just a call from an AMC wanting me to do a rural appraisal. by the time i drive there, do the research, do the report, drive by the comps, etc., i figured i would make about $10/hr on that one. i told them to KMA.

    the bleeding continues . . . . .

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  10. Wayne says:

    Our entire office (both of us) boycott all AMCs! There was a time that I paid dues to AI, NAIFA, IRWA, etc. I still pay dues to one group that I will drop this year. Some of these groups I payed dues and earned designations from I now see as money wasted. It is true that you cannot herd cats and the appraiser group seems to fit that description. While some of us dislike AMCs with a passion and see them as parasites feeding on the weak members of our group. Other appraisers are buying directories and filling out applications with the happy anticipation of being accepted to the group of those being exploited.Those who feed off of the appraisal industry continues to grow. We have the AMCs as well as appraisal organizations, newsletters, coaches, training videos of questionable value, webinars, software vendors, background companies, the list of hacks that want to sign YOUR CERTIFICATION up so that they can earn big bucks…..your neck in the noose! These dudes promote a lavish (at your expense) convention setting where you can pay the freight for not only you but a host of other pitiful SPEAKERS to enlighten you as to how you should do the appraisal thing. Keep in mind that most of these folks are not appraisers and have never done an appraisal but they are here (at your expense) to enlighten you! That is just great!The reality is that those of us that oppose AMCs can simply refuse to work with them. Those that want to work with AMCs should enjoy the experience. I will not spend a dime trying to convince any appraiser to agree with me. I am from the old school and most likely considered to be a “difficult” appraiser. Best of luck to everyone!

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  11. Wayne says:

    so funny….try to post the “real truth” and see how fast your post is deleted.  keep reading…you are in la la land and these silly people keep on …..my goodness,,,remove your head from your ass! 

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    • Wayne, hope you’re not saying that we are deleting any of your comments, because we aren’t. We don’t delete comments unless they’re SPAM. Try refreshing your browser if you don’t see any of the comments you posted as these pages get cached in your browser.

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    • Wayne, we also emailed you several times about publishing one of your comments as an article but you didn’t respond. So not only we are not deleting your comments but we want to publish one as an article. Please reply to our emails when you have time.

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      • Wayne says:

        I tried to respond but the email did not post. You have my permission to use my previous post as you see fit. Thank you for considering it as worthy for an article. 

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        • Thank you Wayne. If you’d like to get credit for it, please email us your bio. We’ll include it at the end of the article. If you have difficulty emailing us directly, you can use our contact page

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          • Wayne says:

            Thank you. My name is Wayne Courtney and I am an appraiser with Realty Solutions Company in East Texas. Our little appraisal company does mostly residential. We have done the high-rise, national guard armories, oil/gas litigation, right-of-way, wetland, floodplain, etc…,most stuff other appraisers did not want.

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  12. Wayne says:

    HEY…I have decided to become an appraisal coach! This is going to be a money making deal as I want all of my viewers to give whatever they can to their local food bank! I do not want a damn dime and think that we should feed the hungry kids in our city. Your choice, do as you see fit!
    Your coach says that if you pay money or provided services to any parasite sucking money from our industry, you are a loser. I am not giving financial advice but AT&T today is 33.63 and paying 5.5% dividends. There are many companies that pay dividends every year and have paid those dividends for 25 to 50 years or longer. Get real…wise up….these AMCs that requre you to “SLAP your mother” are not in your best interest. Look in the mirror….you are better than this! AMCs suck, you know that, they know that! Your coach says this, take the advise…and no charge to you my friend! lets feed the hungry children…they have done nothing wrong!
    I continue because i am mad. How dare some silly SOB try to “coach” other appraisers when they do not know crap about this business? So many people that are collecting fees from appraisers for nothing provided. When you are up to your ears in appraisal assignments and 40 more trying to hire you…ask your $365. coach what to do! Yep, I am mad! Coach my Azz!

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    • Retired Appraiser Retired Appraiser says:

      You sound angry at the real Appraisal Coach Wayne. 🙂  I was once after reading his articles and wrote many an angry response to a few articles.  I finally learned to chill out and admire the guy for trying to make a buck somewhere aside from appraising (God only knows there is no money to be made there).  I still haven’t figured out how he made $400,000 or so per year appraising alone with very little help but I won’t pay to find out how either.  I trust my own gut when it comes to declaring the appraisal profession a dead end JOB.

      We appreciate the fact that you are boycotting AMCs.

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      • wayne says:

        David….after reading my previous posts I agree that I do indeed sound angry. I am not angry at any particular person. I am mad in general that some of us are treated like dogs! I could brag and tell everyone that we turn down so much work that it is often funny! An email today from a RELO company saying that ‘we must contact owner within 24 hours and return appraisal to them within five days! Really? I spoke with a loan officer yesterday who said that the response from appraisers in our area was either not taking any new assignments or refusal to give a due date. Get it when you get it! I just do not really understand that some in our industry are groveling at the feet of AMCs for chump change and others are giving due dates over one month out! I really am not mad and I am sorry if it comes across that way. Within the last year I have spent one week in Hawaii, another in Hot Springs, another week cruise to Cozumel, leaving Monday for Las Vegas and booked for cruise to Belize in November…Really I am not mad! LOL…All I can say is that I wish my fellow appraisers who feed the parasites a wonderful business! Just a question…why do you do that?

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  13. Wayne says:

    Hey my fellow appraisers, I am home after a few days in Las Vegas. My buddy and fellow appraiser met me there and we drove back to East Texas together. Heck we saw the Grand Canyon and 950 miles back to the house. It was fun!

    Neither one of us give a silly damn what an appraisal management company wants to do. From what I can tell by my email from the ASC we lost about 500 appraisers this past month… The lenders cannot find enough appraisers to accept their work now. VA and FHA will be sucking wind in a short time… Appraiser to do WHAT? LOL…wish everyone the best!

    Gee…another call a few minutes ago….seems the appraisal is critical…Sorry, we can only do so much…lets see 3 appraisals per day times 365 days per year at $450.00 or more… Appraiser to do WHAT??? No, we will not do that! Have a great day!

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  14. Lol! makin’ B A N K!

    Sounds good on paper! Three a day? Really?

    BTW lenders have already started lobbying for regulatory approval to fund loans WITHOUT appraisals. They are blaming the need on a shortage of appraisers. I’m SURE we can trust those that got us into the last mess to keep us out of a new one, right?

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    • bubba jay bubba jay says:

      “BTW lenders have already started lobbying for regulatory approval to fund loans WITHOUT appraisals. They are blaming the need on a shortage of appraisers”

      kinda makes you wonder if this has been their plan all along, doesnt it? a lot of things are starting to make perfect sense now. a world without checks and balances. yeah, i see no problem anywhere with that. (sc).

      the bleeding continues . . . . .

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    • Wayne says:

      Hey Mike….Let’s do this slowly one more time. I never said that I did three appraisals each day. Yes, sounds good on paper! Really, I am having a good day if I complete one on average. What I said was that I turned down numerous appraisals. I am human, old, ethical, lazy, qualified to do most any appraisal. However, I can only do so much.

      I have posted that I do NO AMC work, no mortgage broker work, only work with regional banks, credit unions, about five VA appraisals each year, some governmental agencies and numerous individuals, attornies, etc. What I was trying to say….sorry if it made you mad, was trying to say that we were very busy and still turning down 1 to 5 assignments each work day. Let’s just say one at $450. per day for five per work week..equals $2,250. per week or $117,000. per year. If you do not believe this, you most likely would not believe the actual number is more like 4-5 per day. But, just believe what makes you happy. My total and complete POINT in this is that appraisers do NOT need to grovel at the feet of our clients. They really do NEED us, their paycheck depends on it! I wish everyone the best!

      Just one more thing Mike, what if our little office were to accept AMC work? What if we were to accept the large banks, Federal Government, State Highway Department, County, City, Water Utility, School District..Oil and Gas litigation? There must be 2-3 requests per week to “join” our approved list or panel…did I mention that I was old and lazy?LOL

      The intention of my silly post is not to brag. Hopefully it will be to inform my fellow appraisers that we, as a group are needed by many entities and we should hold our heads high. These AMCs cannot stay in business unless they have appraisers to feed upon. FHA can demand that we bounce on our heads while measuring houses…if NO appraiser will do this crap…they WILL change or it is them that will hit the unemployment line! Appraisers really should draw a line somewhere!

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      • Hi Wayne, not sure what I was in my post to make you think you made me mad. I assure you I’m not, and wasn’t. Anyway; likewise intent was not to ruffle feathers.

        I get and generally agree  with your point. The exception is that banks are CURRENTLY drafting or have already proposed seeking regulators permission to fund loans PRIOR to receiving appraisals. It was unclear whether they would then get appraisals post funding or not. Which is a ridiculously risky system.

        You and I know we SHOULD be critically necessary components in the process; but regulators have a history of doing foolish things; otherwise we wouldn’t have these recurring problems every ten to twenty year cycle. I long ago learned that absolutely no one is irreplaceable. There are simply varying degrees of inconvenience when “irreplaceable” leaves or passes on.

        On another note; Following was just passed along to me by Jason Fischman, SRA (& a whole bunch of other super qualifications stuff). He got it from  Ms Rourke, MAI (O’Rourke?) Apologies on name uncertainty.

        “Excerpts from an email (Appraiser Partner News) sent to appraisers on its panel June 11, 2015

        ======================================

        Supervisory Appraiser Change

        Upon review, Red Sky Risk Services, LLC has refined its expectations regarding the involvement of appraiser trainees. Important to note, the following change DOES NOT override specific state statute(s) or appraiser training requirements.

        Effective immediately, Red Sky is no longer requiring supervisory appraisers to be physically present with trainee appraisers at all subject property inspections and driving comparable sales ”

        (end). I believe the rest of her article indicated Red Sky is owned or affiliated with U.S. Bank,

        If this information is accurate, this is probably the most significant, and best news to come out of ANY AMC since their inception! Subject to confirmation of fee amounts being ‘reasonable’, this is the kind of thing that would get me interested in doing loan production appraisals again! IF I can send a qualified trainee to inspect the property, I can AFFORD to accept a nominally lower fee!

        Anyone in an area where these folks are active, please confirm if you can.

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  15. Wayne says:

    Hello Mike,
    Please accept my apology for responding in such an angry manor. I do appreciate that you are doing your part. Yes, I suppose that I am angry. It is not because I am not getting my share of the work or that I am unable to pay my bills. The appraisal business has and continues to be very good to me.

    With about 35 years of experience and a general certification behind me I just really have a problem with a processor or underwriter at a bank giving me a ration. These people do not have enough authority to take off work 30 minutes early but they think they can dictate guidelines to appraisers?

    I do understand that not all appraisers are busy. If they would just take the time to check out other markets they will find that appraisers are needed in many areas. I could write a long list of sources for appraisal assignments that we (both of us) could not possibly even apply too, much less provide services too. If an appraiser is hungry in this market he/she needs to look in the mirror at the problem. Again, not being ugly…just as truthful as I can be.

    With this in mind, the part that makes me angry is that some of my fellow appraisers grovel at the feet of AMCs, etc. that rip them off on a daily basis and do not see that as reality. We do not need a government agency to set C&R….just stand on two feet, quote your fees and they can pay it or they can find a new career. Mortgage lending is not the only game in town. If bank of the universe cannot find a $400. appraiser they WILL pay a $750. appraiser before they lose that loan. If appraisers would just simply say no, or price an FHA appraisal at about $1,500. we will absolutely see some changes there! FHA will do away with all of that crap or it is those government employees that will be looking for a new job. We have plenty of work, let them find theirs! Maybe I am dreaming, but, I am old and gray and turning down more work than I could possibly do anyway. I wish all my fellow appraisers the best!

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    • Wayne says:

      Please allow me to continue my rant for just a minute or so longer. About a year or so ago I prepared an appraisal of a couple hundred acres of timberland/flood plain for an Agricultural Financial Agency. This is the only assignment I had ever accepted from them and it was a PITA. Of course the usual 90 day chase the check game was played! Last week I received a letter from this AG Financial Agency indicating that as a “member of their panel” I would have to take USPAP. (REALLY, these folks actually sent me such a letter) They advised about a page of Blah, Blah, Blah and then stated that THEY would monitor my integrity as a member of their panel! I was told to sign the letter and return to them. Who are these bozos that plan to monitor my integrity? ( I hope they hold their breath waiting on me to sigh and return such an insult) Does anyone believe that they send such letters to home inspectors, surveyors, etc? OK, end of rant!

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  16. Hi Wayne, No offense taken. We all have our issues and tolerance levels. I also think we are mostly in agreement about standing up for ourselves.

    The only item I  disagree on is need for government agencies to intervene. Government agencies created the low fee monster and “C&R” ambiguity  (intentionally). 

    So, for five+ years we  have tried to get AMCs regulated; monitored, filed complaints and tied to get fees modestly raised and turn times reasonably increased. We have done it in  our usual, “independent” fashion, and the results or lack there of  shows.

    Hypothetically IF we  all stopped putting up with the abuse, it would cease. No argument there. If THAT were possible, then there would be no need of state coalitions, or the  Appraisers Guild.

    Lenders suppress the  amounts they pay AMCs. Even when an AMC says they want to pay higher fees, they just don’t have it. Heck, we tried to get a desk review fee for Collateral  Underwriter issues approved and lenders response is that they expect all such issues to be handled within the $450 fee that particular lender pays the AMC. Most pay  $495 to $499. No price fixing there!

    Ultimately C&R will have to originate in the amounts lenders contract with AMCs for.  I think it takes regulatory pressure to  forbid them to contract for amounts that are too low to include  C&R fees.

    A boycott MAY one  day become necessary, but before that happens WE as appraisers all have to be on the same page as to what constitutes MINIMUM “reasonable” fees for  basic assignments.

    Otherwise they just keep playing us off against each other.

    BTW Wayne, I just reread all your posts. Some good stuff in there. You SHOULD take Desiree up on her offer to publish some. It helps us all.

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  17. Wayne says:

    Thank you very much for your comments about my previous posts. I have never claimed to be anything special and only have a very sincere desire for the appraisal occupation to really become a profession one day. Whether it does or not will be no issue that will change my life.

    At the request of an appraisal organization I am a member of I did send a letter to the VA discussing an increase in fee. I only do about five VA assignments each year so personally I do not give a hoot. Explain to me again as a US citizen and a certified appraiser and a Veteran that the government dictates my fee as a professional providing a service? Does the VA demand that a surveyor only charge so much? How about a property inspector, insurance agent, mortgage broker, pest inspector, Realtor, etc…..tell me again WHY the dumba$$ appraiser is the only one whose fees are determined by the VA? Tell me again why the appraiser must extend credit to any bozo mortgage broker and then have to chase them for months to get paid? Really? Welcome to the VA panel! Tell me again why any certified appraiser who is a tax paying citizen of the US must beg to be on the VA panel? They meet the qualifications, why should they have to beg like I did for 12 damn years? An honorable discharge with a general certification and it only took me 12 years to get on the VA panel. Do you suppose there is a problem? Does the VA need to make some changes?

    How about FHA? These folks somehow think that appraisers are a dime-a-dozen and should slap their mother if FHA says to do so! I do not think so! I have been on the FHA panel for decades and have watched their “guidelines” go from pitiful to ridiculous! I am not going to crawl thru an attic or fight the snakes in a crawl space. Not going to happen, they need to back off NOW or look for themselves a new job!

    I have stock in FNMA….. We should close them down immediately, if not sooner, I will donate said stock to St. Judes! Whatever it takes to shut them down! They need to be flushed….just my silly opinion!

    Now, all of these silly appraisal organizations with their stupid “designations”. GEE…I am an ABC, you are only and XYZ. Really??? Who knows, who cares…IT REALLY IS A CROCK…but that is only based on a lifetime of experience! Pay and play if you are willing to waste time and money. Just my opinion…yours will differ!

    There are some of you that are buying “AMC directories” and completing applications to be hopefully accepted to this exploited “panel” of approved suckers! There is absolutely no point in wishing you well. I could wish you well without it costing me a dime….but that is a downhill train. I just want to tell you so!

    This is a strange business right now. We have an appraisal community that is aging and clocking out at about 3% per year and damn near 0% joining up. I personally know many appraisers who are certified and have no interest in appraisals. Some of my “friendly” competitors ( those who do not give a damn) are in their 70’s…..APPRAISER TO DO THIS AND APPRAISER TO DO THAT????…Really? It really is funny to wait and watch what will happen within the next three years. One thing I know is that paying fees, dues, subscriptions, etc. is a waste of money. But if it makes you feel better to attend a seminar where folks who have never prepared an appraisal explain how you should…go for it! LOL

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  18. Retired Appraiser Retired Appraiser says:

    With regard to your question about telling you “why the dumba$$ appraiser” is the only profession that allows their fee to be dictated.

    It’s not just the VA that’s dictating the appraisers fee. It’s the VA, HUD, & AMCs as well. You’ll find the answer to your question within your own question: To be more specific: It’s “the duma$$ appraiser(s)”. To be even more specific it boils down the the fact that all other professions are smart enough to organize and protect their fees which truly does make appraisers the Ace Of Aces when it comes to dumba$$e$. They’ve had the power all along to control their fees but are too lazy and self centered to boycott AMCs, the VA, or HUD to take back control of their fees. Show me a another profession that has demonstrated such selfishness, negligence, and ineptitude and I’ll show you a profession that has long been extinct.

    In the long run the fee grab will be seen as nothing more than a distraction as residential appraisers will be rendered obsolete. Appraisers have a great deal in common with the obsolete Mechas in Steven Spielberg’s film Artificial Intelligence. Your fees will continue to be harvested (like obsolete Mecha body parts) as intelligence more powerful than IBM’s Z13 (real world…not Hollywood) comes online. When the Z?? is introduced and they’ve collected enough data from appraisers, you (the appraiser) will be invited to bid against Realtors and home inspectors for $50 to $100 walk through orders. To summarize, you are being driven into The Land Of The Obsolete by your own clients (banks) and paying out 50% of your fees each month for the privilege.

    All is not lost however; these folks will welcome you with open arms when you reach The Land Of The Obsolete:

    Lamplighters
    Bowling Pin Setters
    Switchboard Operators
    Travel Agents
    Super Market Cashiers
    On Air DJs
    Milkmen
    Type Setters
    Photo Developers
    Elevator Operators

    The Good News
    Appraisers managed to revive a profession that died out in the 1800s (Leech Collectors). Since 2009 tens of thousands of appraisers have struggled to compile contact data for leeches (AMCs) across the country. Leeches were once all the rage for those who administered bloodletting. Oddly enough, appraisers who collect these modern day leeches are the ones volunteering to have their blood drained each month.

    Gigolo Joe

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    • Wayne says:

      RA, I agree with a lot of the messages that you post but I completely disagree with the idea that appraisers are the next buggy whip folks to join the unemployed.

      If I carry my trash to the curb I am walking on real estate. Each of us are standing on real estate while we read my comments or are treading water with real estate below. As we all know, the whole world is real estate. Real estate has no problems. People have problems! What is my home worth? What is the right-of-way worth that the highway department is trying to take from me? I could write all day long about how many situations there are where people need appraisers. There are “some” people that die and leave ..real estate. Heck, they should leave it to me!

      I see where so many appraisers look at only the mortgage lending side of this profession. My little office does mostly residential assignments by choice. Some folks think I am bragging (which I am not trying to do) but there is more appraisal work out there than you can imagine. This is NOT a dying profession! When you do not want an assignment and quote the client a higher fee hoping they will go away, they say…gee, ok if that is what it takes! Really, should be no buggy whip folks in our group.

      It seems that I have blogged more than most. I am sorry for expressing my opinions so often. I thank everyone for putting up with my silly rants and I wish everyone the very best!

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  19. FINISHED!

    Fellow appraisers, please visit http://mfford.com/html/c___r_fees.htm

    Apologies for using my personal site but logistical and time constraints made it necessary.

    It is to read a draft proposal for minimum national appraiser fees. I appreciate some believe no one other than themselves should set fees, and I concur. Except, in the real world of today where someone (lenders and AMCs) are ALREADY SETTING your fees. If not directly, then through ruinous less than customary OR reasonable fee competition.

    Im interested in your meaningful, constructive feedback as well as comment & discussion here.

    For those that insist ONLY regional fees are practical, this same system works for the lowest to highest regions of America. Subtract 13% for low cost areas; add up to 9%+- for higher cost areas.

    Operating premises were:

    1. AMCs are here to stay. Liked or hated, they are part of the chain now.

    2. LENDERS want AMCs to offer one size fits all pricing. This MAY come close to doing so baring complex assignments. Even there, an inferred hourly equivalent is suggested.

    3. If WE don’t set “reasonable” minimums for ourselves, then others will do it for us (or to us).

    4. Framework allows for and includes inducements for trainees or less than certified appraisers-who have been largely excluded or ignored by AMCs in recent years.

    In addition to posting here, PLEASE also email comments to JanBellas@appraisersguild.org

    We are going to start reaching out to state coalitions and other appraiser peers groups. We hope to incorporate helpful comments or views in that effort. In the meantime our parent union is already being contacted to see how we can best proceed.

    Thank you for taking the time to read and respond. Mike Ford, AGA; OPEIU/AFL-CIO

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  20. K. Lorinczi says:

    To the appraiser who is being threatened with non-payment from the AMC unless she changes her report, you can sue that AMC in small claims court.  Whether they are located in your county or not, the small claims suit can be initiated in the county where the property is located or where your office is located – talk to your local Legal Aid office for confirmation of jurisdiction.  Then you go to small claims court and file your suit usually for less than $50.  You can have anyone serve the papers (local sheriffs can serve them) to the AMC and if the AMC does not send a rep to court to fight the claim, you will win automatically.  If they do, you will probably win anyway and by the way – no attorneys are allowed.  You can sue for the unpaid fees, courts costs and the cost of having the summons served.  You will not be out any money.  Provided you can prove they owe you the money (keep the order form) and you performed the service, you should be able to win.  For most AMC’s traveling to your state is not cost effective so they won’t fight it.  Once you have your court order you can seize assets, bank accounts, anything of value from that company if they still don’t pay you.

    It does work.  I used to work for attorneys before becoming an appraiser and I have sued people before without an attorney.  The legal system can work for you.

    Don’t take it lying down.  Fight back. I have fought back against AMC’s who tried to pressure me to change my values and they backed down.  Don’t be a door mat -fight back.  They don’t respect us because we don’t defend ourselves.

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  21. Baggins - Thread Update Baggins - Thread Update says:

    If you enjoy shitty hours and pay
    You're fired

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