I could see perhaps $75 to $100 going to Servicelink but how on earth does ANY amc justify charging more? They certainly do not perform USPAP compliant (SR 3 and SR 4) appraisal reviews.

Even if they did, why should a consumer pay for an AMC to perform the legally required obligations of the lender (to assure delivery of USPAP compliant appraisal reports)?

The appraiser should have gotten no less than $500 to $550 of a $650 gross fee.

WHY WOULD ANY BANK, LENDER OR CONSUMER DO BUSINESS WITH A COMPANY THAT PRICE GOUGES AS BADLY AS SERVICELINK  IS DOING ? Maybe th excessive AMC fee is to compensate them for ‘special assistance’ in getting desired values?

To suggest that there is anything the trained monkeys at an AMC do that warrants a fee that is nearly as much as the professional appraiser receives is simply DISHONEST!

Baggins, I stand corrected. Thank you for the input!

And that’s why it’s essential to properly qualify the client with direct questions about their distribution process, before engagement.

Just one correction there koma, you’ve been stipped!  The amount billed by the appraiser for completion of this order is/was; $XXX.  Do not say the amount paid, since at the time of order submission, you were not yet paid.

Fee disclosure is an ethical matter that supersedes client sow in most typical ml scenarios.  It’s unethical to conceal fees from consumers, aka the primary interested customer party.  My fee is printed on the order page, stapled to the manila folder, then highlighted.  I casually review it every order when at inspection, makes a simple ice breaker to stay focused and gain trust.  Having qualified the clients distribution process before hand, this trust disclosure of fees issue with the customer has never resulted in surprise or confusion.  It’s not my fault that the cfpb approved the unethical hud1 disclosure form that puts appraisers at a disadvantage and does not proper separate the distinctly different fees which is amc and/or distributor vs appraiser.  The consumer deserves better, and so do I.  It’s a free country and I am transparent about fees.

Especially with so many middle manager amc’s in place, and their quite high staff turnover, it’s important to verify the order.  I’ve seen all sorts of data entry and other issues which I corrected by reviewing the order and data with the home owner.  These days the appraisers must quarterback the whole thing, since the middle managers typically bungle as much as they tie up.  Don’t get me started on demanding to speak to underwriters directly, Ha!

VaCap-Bad suggestion.

Most assignments come with requirements not to discuss fees or the specifics of the appraisal with the owners.

Respectfully accepting an order and then putting the property owner or borrower in a confrontational position with our client would be unprofessional (imho).

IF we are going to involve homeowners the time to do it is long before any specific assignment-not after we have already accepted a low fee order.

Who says we cannot ‘discuss’ fees? I again urge all who have not already read the AGA’s proposal for minimum fee calculations to do so now. Its on the AGA website or on my own at http://www.mfford.com (C&R Fees).

Does anyone seriously think that all the banks magically ‘paying’ only from $550 to $600 AMC fees happened without some serious anti trust violations occurring?

The ‘bank’ and AMC agree to a fixed fee. The banks loan officers and correspondent lenders quote that fee to borrowers during the initial loan consultation and application process. There is ZERO input from an appraiser, or analysis of the appraisal assignment by individuals competent to do so. Specific qualifications or competency? You have a license and are breathing, you are ‘competent’.

The fee is cited in the TRID. LOCKED IN STONE by practice and policy!

Only then is an appraisal ordered and the appraiser permitted to “negotiate” within that preset range after the AMC takes their cut.

Tell me again I can’t ‘discuss’ fees with other appraisers! (Not you personally Lauren). My guild represents appraisers. We are a union. Discussing fees is what unions do. I defy ANY agency or entity to attempt to restrict my ability to discuss fees. Want me to prove it?

I heartily encourage every single appraiser in America to adopt a minimum fee for a non complex sfr (FNMA or FHA guidelines) within traditional FNMA non jumbo loan limits of $650. Refer to our C&R proposal for reasons why & possible variations.

Anyone thinks they have an anti trust claim? Go for it! Mike Ford, VP/Chairman NAPRC AGA, OPEIU-AFL/CIO

Lauren, let’s take it back to the basics. If you as a licensed appraiser are engaged in a way that forces an ethical conflict upon you that is; Unacceptable Assignment Conditions. 

For your type of scenario there are good defense mechanisms you can set up in simple client selection methods. “What’s your standard fee in x county? The guaranteed minimum I can rely on regardless of volume. Does your amc charge variable rakes or a fixed fee?” The MB matters, the realty agent matters, the underwriter matters, the appraiser matters. The amc people, their sole job that means anything is the ability to connect the MB and the appraiser together, that’s it, they will never successfully add value services above that because the value is in the appraisers report, and it will always be the lenders responsibility to maintain quality control. The amc is not the client, they are the agent of the client. Amc’s are nothing more than yet another outsourcing and services shuttling company. Without the appraisal report, nothing else matters.

In the USA we have separation of powers for a reason, it’s the effective nature of the checks and balances system. Amc’s make a good illustration how a company will by nature, take advantage of the lack of checks and balances in place. There is never confusion about my fee, because I discuss that fee candidly up front. It’s a professional services fee. Amc’s don’t get to benefit from that, since they are not licensed individuals. Regulating a company is entirely different than regulating an individual. Well, it comes down to us individually to craft our own acceptable assignment condition. 

These amc’s are hiring all these appraiser hopefuls, but they might be surprised how quickly they strike out to 1099’s when they have their own licenses.

That’s why we have to resist! It is your business so why accept. Knowing you got to survive, but at one point 6 yrs ago I went back to my old career part time for a year because would not accept $200 for 2055 nor $295 for 1004. I still got my fee but not as many. I would be losing money at those fees.

So yes there should be protection for us on fees, but on the same token we are our own worst enemy.

Definitely something to think about.

Shhhhhhhh….not so loud.  Homeowners may hear you.

If appraisers had half a brain they would stir homeowners about this situation until the homeowners would become so agitated that THEY would fight back against AMCs; thus doing the work for appraisers.

1. Truly excessive fees like $700 out of $1,700 charged going to the appraiser.

2. NORMAL fees (+-) being charged (for example $550-$600) with appraisers only receiving $450 which has been arbitrarily deemed by the VA to be ‘reasonable’.

In both instances there exists truth in lending misrepresentation. In the first it’s price gouging and in my opinion outright fraud. In the second case it is misrepresentation but not gouging or excessive pricing. Simple lying, if you will.

Small AMCs need a minimum of $75.00 per order to keep their doors open. IF they are doing their jobs; its not an unreasonable amount and they would earn it assuring USPAP compliance and performance by qualified appraisers. Most seek $100 to $150 per order to allow them to absorb customer service related account losses from bigger clients.

Therein lies the problem with what would otherwise be ‘reasonable’ fees for additional appraisal management and coordination fees. $75 to $100 is reasonable. An argument might even be made for $150 on higher end properties involving more administrative work.

Most are driven by human nature and ordinary business objectives to maximize profit. IF it were done with full disclosure of reasonable fees to all parties I’d be hard pressed to find fault.

The problem is that Congress and federal regulators (specifically those Feds that developed the so called Final Rules) implementing DF and TRID. They knowingly screwed both the taxpaying consumer AND the appraisers.

Personally I think any AMC pocketing 50% of the fee charged to the borrower has crossed all remotely reasonable fee boundaries and ventured into outright fraud. Calling something one thing while MOST of the fee goes for something completely different. Then allowing it to be legally concealed under the pretense of Truth in Lending!

Will it change anytime soon?

No. No one really cares and Congress has abdicated its responsibilities in partisan battles to ‘look good’. Could or would President Trump do anything? Certainly, IF the issue was on his radar!

But it’s not on his radar. Doubtful it ever will get the traction needed to show up there.

In the end, the consumer is still unaware of what a reasonable appraisal fee is or why its in their best interests to pay it. All most of them will see is that they paid $600 for an appraisal and the appraiser only got $300. They want their other three hundred back.

The appraiser is still working for half price.

So much for Truth In Lending boys! Consumers are being skinned alive and few have a clue.

Sad to say I have to agree that the consumer won’t look at who is getting how much they will just get angry with the person they have a physical interaction with.