Tagged: R&C Fees

A Possible Solution to Customary and Reasonable Fees - C&R Fees Solutions 10

A Possible Solution to Customary & Reasonable Fees

Over the past five years, a major subject of talk in the appraiser world has been that of Customary and Reasonable Fees. Unfortunately, much of the dialogue has been mostly one-sided. We tend to do a lot of griping about the fact that many of us are not being paid what is “customary” or “reasonable”, but there are very few solutions offered up. When I was young and would sometimes (not often, of course) complain about this or that, my father would always say, “Don’t come to me with a complaint unless you have a possible solution.” It was sound advice then...

Free Enterprise an Appraisal Myth 40

Free Enterprise an Appraisal Myth?

Is THAT free enterprise? I’m surprised anyone in the business today sees any minimum pricing proposal as being anti-free enterprise. Contrary to popular belief we have not had free enterprise in the GSE appraisal process since HVCC first reared its ugly head. AMCs ‘telling’ us to pick a number from $250 to $350, or that ‘THEY pay’ $325 per 1004 is NOT free enterprise. I’m an old timer (1986) that was brought up on what used to be AIREA (now the AI) & SREA (now gone) positions that free enterprise and the Sherman Anti-Trust Act prohibited us from ‘even discussing’...

“Customary” & “Reasonable” Fees Exclusive Oxymorons 10

‘Customary’ & ‘Reasonable’ Fees – Oxymorons

If WE don’t set ‘reasonable’ minimums for ourselves, then others will do it for us (or to us). Fellow appraisers, Please read this draft proposal for minimum national appraiser fees. I appreciate those who believe no one other than themselves should set fees, and I concur. Except, in the real world of today someone (lenders and AMCs) are ALREADY SETTING your fees. If not directly, then through ruinous less than customary OR reasonable fee competition. I’m 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...

An Open Letter to the Valuation Profession from the Appraisal Foundation regarding the rift with the Appraisal Institute 2

An Open Letter to the Valuation Profession

An Open Letter to the Valuation Profession from the Appraisal Foundation regarding the rift with the Appraisal Institute Value. Appraisers grapple with this concept daily as they analyze data and information to arrive at an opinion that is credible.  Some information found is valid, some is tainted, and appraisers work diligently to separate the good from the bad to arrive at their conclusions – opinions that can withstand future tests. Likewise, The Appraisal Foundation (TAF; the Foundation) remains constantly attuned to what is going on in the valuation realm, conscientiously analyzing information and working to uphold the appraisal profession so its...

Skewed Customary Fee Perceptions - Imagecredit Flickr - Quinn Dowbroski 14

Skewed “Customary” Fee Perceptions

I no longer care about “customary”. “Customary” in Dodd-Frank’s customary and reasonable is a negatively biased fee before state studies begin! We all know that the “C” part of C & R is supposed to represent the normal fee charged by most appraisers for similar work and conditions. Some AMC appraisers even know the “R” part is supposed to be an amount that is reasonable based upon ALL factors necessary for completion of the assignment in a USPAP compliant and professional manner. Unfortunately HVCC and the AMC havoc it wreaked has existed far too long for there to be a...

AMC's “My Way or the Highway” Attitude 47

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...

Appraiser-Client Relationship - Imagecredit Flickr - Dennis Hill 15

Don’t You Value our Relationship?

Relationships, we all have them.  And despite the efforts of Dodd Frank to destroy them, we have somehow managed to keep them. A big bank that I had a great relationship dropped me because their portal system decided there were too many appraisers last year and left me hanging. No orders for a year. Now they’re busy and want me to do appraisals. Great! But between the portal fees, underwriting charges, title surpluses, software charges, destination charges, taxes, etc. the fee works out to be substantially lower than most work I have. They asked me “don’t you value our relationship?”. I replied where...

1st Enforcement of C&R Fee Provision Louisiana Makes History - Imagecredit Flickr - Roland Tanglao 5

Louisiana Makes History – C&R Fee

First Enforcement of C&R Fee Provision: Louisiana Makes History Nearly five years after Dodd-Frank set forth rules regarding Customary & Reasonable fees (C&R) for appraisers, an agreement last week between a state board and an Appraisal Management Company (AMC) is the first evidence of enforcement. The bottom line for appraisers is that they may be finally on their way back to customary and reasonable fees. On June 4, 2015, the Louisiana Real Estate Appraisers Board (LREAB) issued a Stipulations and Order Memorandum (SOM) wherein Coester Appraisal Management Group, also known as Coester VMS, offers no admission of guilt but agrees...

Louisiana Real Estate Appraisers Board (LREAB) Resolves AMC Complaint - Revised Press Release - Imagecredit Flickr - Nic McPhee 1

LREAB Resolves AMC Complaint – Revised Press Release

Louisiana Real Estate Appraisers Board (LREAB) Resolves AMC Complaint Baton Rouge, LA – – On June 4, 2015, the Louisiana Real Estate Appraisers Board (LREAB) approved entering into a “Stipulations and Order” with Coester VMS Appraisal Management Group. The Order will resolve a pending complaint that alleged that Coester violated Louisiana law that requires AMCs operating in the state to “compensate appraisers at a rate that is customary and reasonable for appraisals being performed in the market area of the property being appraised, consistent with the presumptions of compliance under federal law” (La.R.S. § 3415.15, La. Admin Code. tit. 46,...

The Louisiana Real Estate Appraisers Board Holds the First Hearing for AMC’s Not Following the Laws and Rules for Determining Minimum Reasonable and Customary Fees - Imagecredit Flickr - GotCredit 16

AMC Fined for Reasonable and Customary Fees Violation

The Louisiana Real Estate Appraisers Board Holds the First Hearing for AMC’s Not Following the Laws and Rules for Determining Minimum Reasonable and Customary Fees As a result of a thorough investigation conducted by The Louisiana Real Estate Appraisers Board (LREAB), an adjudication hearing for an appraisal management company was held to determine if that firm is following the laws and rules pursuant to minimum reasonable and customary fees, as required by the Dodd/Frank Act and Louisiana laws and Appraisers Board rules. The case alleges the appraisal management company Coester VMS was not compliant with the state’s AMC laws and...

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