Tagged: Reasonable & Customary Fees

February 20, 2014

Usual & Customary? According to Who?

Try this method of “price fixing” in any other business and see what happens! The “marketplace” usually sets what is considered “customary and reasonable”. Imagine asking attorneys to base their fees on what some government official (who knows nothing about their business) decides is “customary and reasonable”. It would NEVER EVER work, and should not be part of the appraisal (or any other) industry. It’s absolutely price-fixing which I always thought was illegal. The HVCC started all this focus on the appraisal industry and everybody is so busy trying to remake the appraisal industry, the banking industry quietly slips away,...

Appraisal / Appraisal News / Appraisers News / Customary & Reasonable Fees / Dodd-Frank Act / C&R Fees

April 22, 2013

North Dakota Governor Signs AMC Law

AMC Law in North Dakota North Dakota became the 37th state to enact a comprehensive law requiring the registration and oversight of appraisal management companies on April 12 when House Bill 1389 was signed into law by Gov. Jack Dalrymple. The law takes effect on Jan. 1, 2014. Under the new law, entities involved in the residential collateral valuation process must register with the North Dakota Real Estate Appraiser Qualifications and Ethics Board if they oversee a panel of more than 15 independent contract appraisers in North Dakota or 25 or more nationally. Entities that exclusively employ appraisers on an...

AI / AMC / Appraisal / Appraisal Institute / Appraisal Management Companies / Appraisal News

January 30, 2013

Evaluation Solutions Failure

Evaluation Solutions, LLC: The Anatomy of an AMC’s Failure and Why Lender’s Should Care Last week, I had the pleasure of speaking to the Collateral Risk Network about lender oversight of appraisal management companies. With that exciting topic as my general theme, I chose to address the specific issue of AMCs failing to pay independent contractor appraisers for appraisals ordered by the lender-client (and also failing to pay agents and brokers for BPOs). This issue has been brought to the forefront of many appraisers’ minds and bank accounts by the recent failure of two large AMCs: National Real Estate Information...

AMC / Appraisal / Appraisal Management Companies / Appraisal News / Appraisers News / Customary & Reasonable Fees

January 16, 2013

CoesterVMS Flat Fee Appraisal Structure Controversy

Lately, there has been some controversy surrounding the announcement of CoesterVMS implementation of a flat fee appraisal structure which went into effect on January 1. The announcement appeared on CoesterVMS Blog on January 7: CoesterVMS, a nationwide appraisal management company, has implemented the appraisal industry’s first ever flat fee model for residential appraisals. Under the flat fee model, which took effect on January 1, 2013, all conventional appraisals for mortgage lenders are priced at $450 while FHA appraisals are $475*. Customarily, appraisal management companies utilize a tiered fee structure, whereby prices are determined based on the property type or the...

AI / AMC / Appraisal / Appraisal Institute / Appraisal Management Companies / Appraisal News

November 7, 2012

Texas Appraisers and AMC Survey

In August 2012, the Texas Appraisers and Appraisal Management Survey surveyed a total of 1,584 appraisers and 55 appraisal management companies doing business in the state of Texas. The questions were specifically designed to achieve the following: Clearly distinguish between the fees paid to appraisers by Appraisal Management Companies (AMCs) and fees paid by non-AMC clients for residential appraisals. Capture any difference in fees paid by property type: single family, condominium, size or square footage, or other factors. Capture the impact on fees by market area or locale: urban vs. rural, (MSAs, county, zip code, etc.). Determine whether appraiser qualifications...

AMC / Appraisal / Appraisal Management Companies / Appraisal News / Appraisal Organizations / Appraisers News

October 22, 2012

Appraisal of the Industry

Of course any one who has bothered to open USPAP, or read the preface of any appraisal related book is very likely familiar with the valuation process. definition of the problem preliminary analysis data collection highest and best use analysis estimate of land value application of the three appraisal approaches: cost, market, income reconciliation of value estimates report of value Of course the application of this definition and process is where the fun begins. Definition of the problem… If I do not complete this report within the allotted 48 hours that has been so graciously allowed by the high pressure...

AMC / Appraisal / Appraisal Management Companies / Appraisal News / Appraisers News / Customary & Reasonable Fees

June 29, 2012

AGA Statement to House Financial Services Committee Hearing

The American Guild of Appraisers Statement to House Financial Services Committee Hearing Madam Chairman and Members of the Committee, on behalf of the American Guild of Appraisers/OPEIU Guild 44 (AGA) thank you for the opportunity to submit this statement in connection with today’s hearing on the real estate appraisal profession and the regulation of appraisers and appraisal practice. The AGA is a membership organization that seeks to represent the interests of appraisers related to federal and state regulation of appraisal practice and to industry practices that impact on appraisers and appraisals. In addition, working closely with other like-minded organizations including...

AGA / AMC / Appraisal / Appraisal Management Companies / Appraisal News / Appraisal Organizations

June 28, 2012

Statement of Frank Gregoire (NAR) Before Appraisal Oversight Hearing

NAR believes that lenders should be prohibited from retaining the services of an AMC where the lender maintains any level of ownership. Frank Gregoire‘s written testimony to the United States House of Representatives Committee on Financial Services Subcommittee on Insurance, Housing and Community Opportunity before the Appraisal Oversight Hearing … APPRAISAL ISSUES AND CHALLENGES There are a myriad of circumstances and issues working to hinder the recovery of the nation’s housing market. Among them, and often overlooked, are those related to the credible valuation of real property. A credible valuation provided by a licensed or certified professional 1) ensures the...

1004MC / AMC / Appraisal / Appraisal Management Companies / Appraisal News / Appraisal Organizations

May 31, 2012

20 Reasons Appraisers Should Get Paid Full Fee

JIM THORPE, Pa., May 24, 2012 /PRNewswire/ — Rick Grant of RGA Public Relations and Jeff Schurman of Leading Causes have released an industry white paper entitled “The Appraisal Management Company Full-Fee Hypothesis.” This is the first paper in a series the two plan to write in 2012, while also working with a number of mortgage technology thought leaders to produce other papers. “I’m very proud of the work we’ve done on this paper,” said Grant. “While the conclusions we have reached are bound to stir up controversy, this is an issue the industry needs to start taking very seriously....

AMC / Appraisal / Appraisal Management Companies / Appraisal News / Appraisers News / CFPB

April 2, 2012

Questions & Comments RE Customary and Reasonable Fees

Where To Direct Questions and Comments Regarding Customary and Reasonable Fees The appropriate agency to receive your concern about a creditor’s compliance with the Truth in Lending Act (TILA), including the requirement for the creditor or the creditor’s agent (including an AMC) to pay an appraiser a customary and reasonable fee, is the agency that enforces TILA with respect to the creditor. With respect to insured depository institutions of more than $10 billion and their affiliates, the Consumer Financial Protection Bureau (CFPB) is the appropriate agency. For other non-depository institutions, the appropriate agency to receive the complaint is the CFPB...

AMC / Appraisal / Appraisal Management Companies / Appraisal News / Appraisal Organizations / Appraisal Subcommittee