Agree 100% We DO have legitimate reason to wonder if bribery or other inducements such as jobs when they lose theirs as commissioners, have been promised.

Or, the fact that these agreements that cap all fees within the above amount are made PRIOR to any specific loan application being made?

Or, the fact that borrowers are quoted “appraisal fees” based on the above at the subsequent time of their applications?

I agree with the earlier poster. I DO wonder if their motivation is honest. With only two commissioners and both prior administration carry overs only taking an interest under the new admin seems peculiar. They had nearly eight years to address this BEFORE.

“One problem leads to another, one regulation creates two new problems. / It is a very dangerous situation because they accept this principal that government insurance can substitute for what they’re doing.  But it’s not insurance it’s just government interventionism to cover up their mistakes.  This is certainly what has happened in the housing program.”

People use the term free markets quite often, but without a proper understanding of what that means, these sorts of bureaucratic calamities typically ensure.

Exactly.  I know advocacy when I see it, and the FTC clearly just advocated on behalf of amc’s.;

We question whether it is appropriate for appraisers to receive the full rate that the consumer  pays. Typically, the consumer pays for additional services beyond the appraisal (e.g., other services provided by the AMC

That would be the illusion of value added services, unearned fees, basically what equates to a junk fee.  The amc does not provide services to the consumer, they provide services to the lender.  The lender should pay for their services, and nobody else.

Any arguments about protecting consumers falls flat for this exact reason;  When cost savings are achieved by way of a lower appraisers fee, those cost savings are not returned to the consumer and are otherwise pocketed as a variable unearned and junk fee.

The very presence of amc’s has driven up consumer charges nationally many hundreds of dollars, but rarely do appraisers see any of that fee increase.

Additionally this is a clear message to lenders the models are not working and they should simply stop using amc’s.  Well over 50% of the entire appraiser populace quit this industry due to anti competitive practices of amc’s.

If it’s war you want FTC, appraisers will more than happy to bring it to your door step.  Appraisers are fed with AMC and legalized extortion.  Don’t think for a second they won’t put up a fight over the tiny gains made on their behalf by a handful of state boards who cared enough to assist them in fighting back.

Don’t issue your hollow threats towards state appraisal boards.  Bring it on or STFU.