I guess the efforts of AI Members to monopolize 1-4 unit AMCs has come full circle. Can’t wait til we see commercial appraisers with 20+ years experience complaining about $700 to $1,500 AMC splits. Oh wait, THATS already here!

Dear VaCap your own quote pretty well answers all the questions you asked.

“The Mortgagee must ensure that all fees charged to the borrower comply with all applicable federal, state and local laws and disclosure requirements”

In the AMC’s world view clearly the certified appraiser meets all the HUD requirements for education, training and licensing level or he would not be on the HUD/FHA approved roster. Evaluation of qualifications done! Requirements met.

The Fed (including Dodd-Frank) put ALL of the burden for compliance on the mortgagee or lender. Enforcement of that (and all other state and federal laws and regulations) are put in the voluntary hands of the individual states.

The states in turn then reinterpret USPAP to suit their specific enforcement or revenue goals. At least up to 24% of them may do so according to information derived from the Isaac Peck (WorkingRE) article of early 2016 do.

The ONE thing that both FIRREA and subsequent State Appraisal Laws all claim is their top priority “To Protect the Public Interest & Trust in the Appraisal Process”, is the most important and glaring failure ever to arise out of the S&L Bailout; TARP and or Quantitative Easing I, II and or III.

The ONLY thing taxpayers demanded was “Protect us from ongoing, repeat failures from the same root causes happening every 15 to 20 years!”

…and apparently THAT is what legislators and regulators heard. The next scheduled failure has been accelerated to 10-15 years and should hit between 2019 and 2024. Worrying time is reduced by a full five years!

Until federal legislators are willing to write an enforceable Bill to be passed into Law that follows a specific carefully and clearly explained, unambiguous requirement with similarly clear FEDERAL ENFORCEMENT legislation American Taxpayers will continue to be the private piggy banks of special interests.

Protected by the likes of the Oregon, California, Texas, Maryland, Illinois, or Minnesota Real Estate Appraiser Boards. Y’all remember Oregon and its contention that on-time report delivery was a USPAP requirement? Or the other 11 states they consulted with for that egregiously incorrect consensus?

It’s doubtful the positive regulatory efforts of Virginia; North Carolina and a remotely distant third Louisiana will be enough to preserve taxpayer and consumer interests.

3/4 of us will be retired by the time any of these “new” assistants have 5 years under their belt.

Wait and see, both shoes are about to drop! Enough time has passed that the loans that have appraisals ordered through AMCs are starting to go bad. When the investors and insurers of the loans start digging into the loan files, the appraisals will be targeted. This will open up the liability of the AMC! After all, the AMC is responsible for ordering and reviewing the appraisal report. Qualifications of the appraiser will be in question, how the appraisal was assigned, even the “revision requests” will all be exposed.

Just image for a moment, in a court of law, a Judge asks the owner of the AMC the qualifications of the person who reviewed the appraisal. Their response “They got a good reference from Taco Bell ” Do we need to say more?

Thanks for supporting VaCAP.

It is criminal what they have allowed !!! We get email and calls all the time from AMC’s looking for a cheaper, faster appraiser, The email reads….”we have a new client and want to impress them”……Sound familiar ???

Sometimes almost 2 hours away !!!

Standard fee of $250.00+50.00 FHA fee for additional inspection requirements. Total fee to appraiser=$300.00

Total Fee AMC/FHA fee charged to borrower=$750.00

Borrower wonders why they are getting screwed and thinks appraiser is greedy, while the AMC will not disclose fee paid to the appraiser and will not allow the appraiser to include an invoice.  (WOW THIS IS A GREAT SYSTEM!)

AMC pockets $450.000 for doing ABSOLUTELY NOTHING while laughing to the bank!