If amc’s and direct distributors alike, having direct unrestricted access to the ‘appraisal fee’, can price gouge consumers and rake in secret from appraisers, I think it’s only fair they allow mortgage lenders to get in on the action and charge some superfluous fees.  Why should the appraisal order distributors get such a break when others are held to all these long standing standards?  I do believe it should be o.k. for appraisers to just raise the fee midway without needing any justification.  There is no standard for how much is o.k. to take out of the appraisal fee for management.  Am I the only logical participator in this industry whom thinks junk fee and unearned fee rules are unfairly implemented when they apply to everyone except handlers of appraisal orders?  Can I start double billing to recapture the loss, and like send title a bill for use of the report?  How can I get in on this unrestricted unfettered earning and raking variable ever increasing fees game?  It’s going on all around me, around this entire industry.  It must therefore be legal and acceptable practice.

It’s the co mingled fees. A simple but absolute requirement that the appraisal fee charged to borrower must be paid 100% to the appraiser, no sharing, would return literally billions of dollars back into appraisers pockets very quickly. Also this would remove the incentive to select by fee for many companies, and there would be far better balance in terms of fair distribution. No more enticement by low fee approaches, but if appraisers wanted to work for less to save borrowers money, they’re free to do so. As it stands now with co mingled fees, there is too much room for abuse and the pattern of abuses is continually expanding.