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”
and another
“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:
| Richard Cordray The Consumer Financial Protection Bureau P.O. Box 4503 Iowa City, Iowa 52244 Appraisal_Tips@CFPB.gov |
Thomas J Curry Comptroller of the Currency 400 7th St, SW Washington, D.C. 20210 |
| Janet Yellen Federal Reserve Board 20th Street and Constitution Avenue, NW Washington, D.C. 20429 |
Martin Gruenberg 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.
- VaCAP Supports Shane Lanham’s Legal Fight - September 10, 2024
- It’s Just Responsible Journalism! - February 21, 2024
- Limitations for Damages Against Appraisers - January 9, 2024
Fara Canterberry check this dude out ?
If I can play devils advocate I would say the issue is not a single Mr. $225 appraiser, but rather there are tens of thousands of Mr. $225 appraisers. Wells Fargo is the single biggest lender in the US, and although they just sold the rest of their AMC, “RELS” they have been offering semi-difficult assignments in my area (average price $900,000) for years in the range of $245. They have their own desk reviews that pay $45. The message may be the same “say NO to low fees” but in my area I would need thousands of appraisers to say no before the wages would every increase to a customary and reasonable level. If you live in Idaho Falls where house prices are $186,000 and rent is $600 (cost of living / bankrate) then that same Mr. $225 appraiser may be able to make a living. When quoting individual fees its very important to provide context and to understand what part of the country you live in. I support the individual appraisers ability to file complaints, but it should be no secret to the Richard Corday’s of the world that the abuse is on full display directly under there noses.
“Belonging to the appraisal profession today is like being a member of a Carpenter’s Guild and knowing that 40% of your members are termites.” ~ Retired Appraiser
An even larger problem Bill is the legion of $75 appraisers. Remember all those employment ads that are posted on your protector’s (Appraisal Institute’s) website? The ads are for direct hire appraisers for AMCs (their in house appraisal staffs). Then you have the appraisal mills (sweat shops); most pay the appraiser around $75 for each completed order and insist that you complete 2-3 each day.
After you take the sweat shop appraisers and the in house appraisers into account Mr. $225 suddenly looks like a genius. The guy who wishes to be a professional and bill professional fees for his services has no chance when forced to compete directly with three subspecies of the appraiser neanderthal.
I haven’t looked at the AI’s employment site for years but I would be willing to bet that 75% of the jobs advertised are still Appraisal Sweat Shops or AMCs searching for direct hire appraisers. That is the extent of what the Appraisal Institute is doing to assist residential appraisers; enabling others to undercut the fee of the professional. If the AI had any brains they would refuse advertising space to AMCs and Appraisal Mills.
If he raises fees he could get a haircut!
are these coalitions just plain stupid or what?
allow me to enlighten them.
appraisers take jobs for $225, because appraising is the only job they have. appraisers take jobs for $225 because they need a roof over their heads. appraisers take jobs for $225 because they and their families need to eat. appraisers take jobs for $225 because they cant afford to say no.
just because an appraiser is forced to take a job for $225, doesnt mean the fee is customary and reasonable. I WILL NEVER bash any appraiser for wanting to eat, or wanting to keep a roof over their families heads. i will do anything to keep my family fed and a roof over their heads. just saying “no” looks easy on paper, but in the real world, it just isnt possible for some. is it extortion when greedy banks/AMC’s force appraisers to work for unreasonable fees, so appraisers CAN eat and keep a roof over their families heads? you decide.
appraisal fees frozen in 1990 are NOT reasonable, and anyone who thinks otherwise is delusional. fees controlled by outsiders is not free enterprise. are appraisers self employed and in business for themselves, or arent they? any outsiders who control what appraisers get paid in their businesses, sound like employers to me. appraisers being forced to accept ridiculously low fees, continues to ruin the profession and appraisal businesses. appraisers forced to work for such fees are being run out of business. greedy banks/AMC’s who force appraisers to work for 1990 fees or anything other than reasonable, are only shooting themselves in the foot. current statistics show that we are finally starting to see the problem of greedy banks/AMC’s who continue to force appraisers to work for unreasonable fees, starting to come full circle now.
appraisers who are forced to work for unreasonable fees, will eventually have enough of ALL the nonsense, will someday wake up, and will not renew their licenses because they have realized that their businesses have gone broke and they refuse to work for free anymore. fees frozen in 1990, and costs going up every year since, is a recipe for disaster for any business. pretty soon banks and AMC’s wont be able to find any appraisers to work for them because all the appraisers will be gone. greedy banks/AMC’s are driving appraisers and THEMSELVES out of business, but they are just too stupid to realize it.
the appraisers arent the ones at fault here. the problem lies with anyone who has control over appraisal fees, and hasnt adjusted them in 20 years, so appraisers can remain in business and make a decent living. if appraisers had a CHOICE, no appraiser would work for 1990, or ANY unreasonable fee. every appraiser should be paid as the highly-educated professionals they are, and not like a manager at Taco Bell. that isnt reasonable.
until EVERY appraiser gets full control over their fees, more appraisers will continue to be run out of business, more appraisers will leave the profession, the profession will continue to implode, and the bleeding will continue . . . . .
We should all move to Idaho Falls where rent is $600 and Mr. $225 Appraiser only has to complete 2.66 appraisers a month to be able to afford rent. Or if he’s lucky, that Idaho appraiser could complete 1.33 VA appraisals ($450) to pay rent. Some who make $225 per appraisal can live like kings, while others may qualify for significant government assistance and live below the poverty line at the same rate.
just like walmart….without the sweet vest!
I do not see these groups as being stupid. What is wrong with educating your peers? What is the problem with discussing fees? What is the problem with sharing data and sources? I think the people against these groups are the amc as they are worried about meeting a united group who will require a customary and reasonable fee for the markets they represent.
Waaambulance time for bubba. Your inability to be a studious money manager is your own downfall. A rice warmer costs 20 bucks at wllmrt. It lasts a decade. A 20lb bag of rice costs 10 at costco. Butter, salt, spice, and frozen veggies cost another 20, and will last months. You’ll save so much on meals, it will be no problem to roll out a steak. If your cc is more than 12%, you’re doing it wrong. If you roll debt into your mortgage, you’re doing it wrong. If you cannot sell the service at the level you require, you’re doing it wrong. Statements regarding anyone being able to force an appraiser to do anything, are not reasonable statements. Nobody tells me what to do. What your problem is, will remain a mystery. Some good solutions include broader marketing. I’m approved with most of the amc’s in my state. We play a continuous game of musical chairs where I bounce orders all the time, with my absolute minimum 450 full order requirement. As soon as they’re willing to pay, I accept. If they try and take advantage and are only willing to pay for complex, the fee goes up. You’re missing the big picture; Appraisers represent the checks and balances system in mortgage lending. Of course lenders would rather see us out of the picture, so they have no check to the balance. It is the appraisers own responsibility to demand fair fees, and accept nothing less. Just like in any business, the market drives the demand and the price. For every appraiser who accepts less than they think they’re worth, well, that’s just another example of an appraiser who is unwittingly setting the fees for their own market presence. Your fee is your fee, and nobody elses. When amc’s and distributors throw you lines about trid, paperwork, and prenegotiated fees, the constant appraiser response is; If you can’t negotiate a fair fee, step out of the way and let me handle that. My minimum is $X, and that is non negotiable. Market more and play the game of substitutability. I find it rather entertaining how an amc will play the market substitutability game in their own favor, but will immediately short circuit when those same principals are levied back to them, to their disadvantage instead. The cake is a lie, so don’t eat it. Bake a new one. It is obvious that lenders are virtually above the law these days, which is why ‘junk fee’ rules apparently do not apply in the realm of appraisal distribution.
Here’s an example for you Richard Cordray fresh off the presses as to what the typical appraiser is up against. Do you think the lender cares that I worked this area as new construction, that I’m aware of the errors as it relates to public record files verses stated builder brochures GLA, that the property has an adverse location, that the market value is near $800,000, etc.? Of course not, as I received the following response to my requested higher fee.
“I’m sorry, the best we could do is $350.00. The lender has specifically asked that we stay within our standard fee pricing.”
In other words, they could care less what the local expert in the field says as they have locked in the appraisal fee via TRID requirements and are staying within what they have determined to be standard fee pricing. Insert in my area Mr. $350 Appraiser who will compete this $650 assignment at the standard fee.
Here’s an example for you Richard Cordray fresh off the presses as to what the typical appraiser is up against. Do you think the lender cares that I worked this area as new construction, that I’m aware of the errors as it relates to public record files verses stated builder brochures GLA, that the property has an adverse location, that the market value is near $800,000, etc.? Of course not, as I received the following response to my requested higher fee.
“I’m sorry, the best we could do is $350.00. The lender has specifically asked that we stay within our standard fee pricing.”
In other words, they could care less what the local expert in the field says as they have locked in the appraisal fee via TRID requirements and are staying within what they have determined to be a standard fee pricing. Insert in my area Mr. $350 Appraiser who will compete this $650 assignment at the standard fee.
TRID has absolutely NOTHING to do with appraiser fees.
Please tell us Clark why TRID has NOTHING to do with appraiser fees?
I have found nothing that mentions appraiser performance, review, fees or, compliance in the guide.http://files.consumerfinance.gov/f/201508_cfpb_tila-respa-integrated-disclosure-rule.pdf
The amc and lenders may try to use TRID as an excuse…educate yourself and other appraisers.
Great article. Thanks VACAP. Unfortunately, Mr $225 appraiser is AMCs’ favorite.
Clear Capital email blasts are proof of that. I don’t know how I ended up on their panel but I used to get their email blasts. Their appraisal fees for million dollar properties was $225 and $100 for their enhanced desk review. Heard their fees haven’t changed much. Don’t you love the part where they say the assignment is granted to the 1st appraiser who accepts the request? Of course, they’ll tell their clients that they only use highly professional and experienced appraisers, and chose the highest rated, geographically closest appraiser for each assignments. That their ratings are based on overall valuation quality of prior reports, responsiveness and professionalism. NOT THE LOWEST FEES?
I know for a fact that Clear Capital is/was charging a govt. contractor $650 per appraisal, and broadcasting at $260. They are, by far, the worst to work with as a client too. A client can expect to wait upwards to 2 weeks for an appraisal, and it be riddled with errors! iMortgage is a nightmare. They claim to have appraisers completing 1004 for $250, and their people are pushy and incompetent. Solidfi has been pretty good to me, although they have never done anything to deserve the $85 that they make per report of mine. The one thing that is true amongst ALL AMCs is that they absolutely do not employ anyone that knows anything about the appraisal process.
I talked to Clear Capital regarding the appraisal acceptance time. They stated that they give the appraiser approximately 4-5 minutes to accept this appraisal request. 4-5 minutes!!!!! Are you crazy!!!! I went to take my morning constitution and lost 4 requests!!!! I told them that is not enough time for me to pull the subjects data and determine if there is any issues with the request. How can we as appraiser use due dilligence when this kind of AMC practice continues to go on. WE MUST STOP USING CLEAR CAPITAL and any other AMC that “Broadcast” the requests. They wanted me to do a 10 acre subject with comparables out 10 miles in all directions for this miserable fee. I would make about $10 an hour after all is said and done. I can’t run a business on $10 an hour!!! I asked them “how do I contact you to inform you that this is a difficult appraisal when you only give me 4-5 minutes to accept it? No answer of course.
Clear Capital would send me these assignments too, I would respond with my C & R fee. In some cases they would agree and I would get the assignment. However…the requests for “corrections” and revisions which always contradicted the previous request weren’t worth the fee. Most of time the revisions were because their software couldn’t read my software. And generally they were the ones for JP Morgan Chase because their software couldn’t read mine. I try and stay away for anything having to do with JP Morgan Chase after what they did to all the appraisers who worked with ES and got screwed.
Amen!!!!!
Low fee appraisers are part of the problem with many of them being unqualified. Time for all appraisers to step up to support the profession and the future!
Join the American Guild of Appraisers. http://Www.appraisersguild.org or call 301 220 4100.
I am 100% in agreement with the article.
In other words the lender as specifically directed them to disregard Dodd Frank’s Mandatory requirement that the fee be “customary and reasonable” for the nature of the assignment. If Mr. Cordray wont do anything, then take it to his ‘boss’ at ASC. Send specifics to jim@asc.gov
Clark A. Davis that’s not actually true. It shouldn’t have anything to do but it is used as the excuse.
Rotational distribution solves all woes, and removes the incentive to undercut the competition. Solutions are so simple, nobody dares consider them.
For years, I did not raise my fees because I was afraid I would lose clients. I had built up a base of a few steady AMC clients that sent work and were relatively easy to work with. Then I got a new client who had lots of work, told me the C&R fee in my area was $325 and desperate, I accepted it and got lots of work but they had lots and lots of revisions on each report and it was very annoying and time consuming. When I complained to their vendor management department, they told me to raise my fees. I was astonished at the possibility but did so. They continue to send lots of work and don’t care that I charge more. I have also increased my fees across the board for all other clients and am no longer afraid to ask what I think the assignment is actually worth versus what I think I can get. I am making more money and working less than before and have not lost any business volume due to my higher fees. There is a shortage of certified appraisers in my area and those still active are in high demand. Lesson learned: don’t be afraid to ask because you might just get what you want. If you don’t ask, you probably won’t get it. AMC’s are in the business of making money. They don’t care personally about appraisers or their welfare. They just want to make money.