Mr. $225 Appraiser and VaCAP
Mr. $225 Appraiser, you are a major contributor to the problem
Recently VaCAP has been receiving correspondence from Virginia Appraisers complaining about low fees and AMC abuses. Comments like the
“The AMC is taking more than half of my fee”
“Why hasn’t VaCAP done something?”
One of the best yet…
”When is the Customary and Reasonable Fee Committee meeting? I can’t keep accepting appraisals for $225“
This came two weeks after the Customary and Reasonable Fee Committee meeting!
Well Mr. $225 Appraiser, what rock have you been under? VaCAP sends out information on a regular basis; on average of once a week. We have announced the dates, times, locations of all the meetings. We have explained what the Townhall is; why you should register, and even provided a link to the site for you to register! We even post on Facebook. Mr. $225 Appraiser, the AMC taking half your fee is nothing new. This is one of the main reasons VaCAP was started back in the 2011.
Mr. $225 Appraiser, why are you not a member of VaCAP? Why are you not a member of any other appraisal organization? Why should all the volunteer members of VaCAP continue to work for your benefit? Why are you unwilling to help yourself? Why do you continue to accept fees below customary and reasonable? As long as you, Mr. $225 Appraiser continue to accept assignments below customary and reasonable fees, they will continue to be paid. Mr. $225 Appraiser, you are a major contributor to the problem, and not part of any solution. Why Mr. $225 Appraiser, are you unwilling to help yourself?
VaCAP is willing to help any industry professional with any situation. We even help members of other coalitions in other states. Is it really too much to ask that you be willing to help yourself first?
From the Appraisal Subcommittee Website:
Appraisal independence requirements for consumer credit transactions secured by the consumer’s principal dwelling are set forth in 129E of the Truth in Lending Act (TILA). Other appraisal independence (or appraisal independence) requirements are established by various Federal and State statutes, regulations or guidance. Examples of violations of appraisal independence laws could include:
- an appraisal management company failing to pay an appraiser a customary and reasonable fee for appraisal services.
- withholding payment of appraisal services to influence the outcome of an assignment
- an appraiser failing to act independently and impartially in the development and reporting of an assignment’s results.
- a financial institution’s loan production staff attempting to improperly influence an appraiser’s opinion of value.
- an appraiser failing to disclose a financial or other interest in the property that is the subject of an assignment.
- excluding an appraiser from consideration for future assignments because the appraiser reported a value that did not meet or exceed a predetermined value.
- implying to an appraiser that future retention depends on the amount at which the appraiser estimates a value to be.
Mr. $225 Appraiser, the time has come for you to step up and be a professional appraiser, support your industry, our future, and protect the public. Here is who to contact with your complaint:
The Consumer Financial Protection Bureau
P.O. Box 4503
Iowa City, Iowa 52244
|Thomas J Curry
Comptroller of the Currency
400 7th St, SW
Washington, D.C. 20210
Federal Reserve Board
20th Street and Constitution Avenue, NW
Washington, D.C. 20429
Federal Deposit Insurance Corporation
550 17th Street, NW
Washington, D.C. 20429
When filing your complaint, make sure to provide documentation as well as the lender involved. The lender is the one responsible for their agent, the AMC.
The Virginia Coalition of Appraiser Professionals is a 100% volunteer organization. We exist to unite, preserve and promote the appraisal profession in Virginia. Public Trust and Appraiser Independence are of the utmost importance to us.
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- Federal Valuation Agency Impact on Appraisers & the Public - July 22, 2022