Be assured there is a master plan at work. These are sharks not nieve lambs. It will eventually become apparent in the coming months.

It just makes no sense. If appraisers die on the vine, AMC’s will have nothing left to pillage.

Yes, I immediately revised this feature. It’s funny how they got in front of it by sending me an email telling me how to disregard the feature the same day they released the update. It was like, “We’re sorry, we know this is annoying so here’s how to unf$%k it. You can’t even describe the condition of the flooring without a “bad” word these days. Needless to say, I don’t sleep very well lately due to the anxiety the GSE’s & HUD have created. It’s like playing “whack a mole” every time I complete an assignment – It’s exhausting. Is it a coincidence that I buy more lotto tickets these days?

Simply incredible. A substantial group effort will be required to go through and highlight the commentary. 950+ comments. There appear to be quite a few new comments in the 400-950+ comment ranges which may be worth reading, submitted in just the past few days. Reviewed last few dozen and there were a few unique appraisal focused comments.
Comments
https://www.regulations.gov/docket/CFPB-2024-0021/commentsmments.
https://www.regulations.gov/document/CFPB-2024-0021-0001

This is interesting. Reactive Reddit appraisers, following up here slightly later on in time. The Jr crowd quite often whom is still bright eyed about ‘amc opportunities’. Someone should show up there and tell them to come here instead for better real time accurate information.
https://www.reddit.com/r/appraisal/comments/1egwq7q/lack_of_fee_transparency_exposing_the_amc/

Mr Turner, could you please post the comment deadline extension link if you have, was not able to find. Thank you.

Comments to the CFPB has been extended until August 15. Everybody get up off of your arse and do something for this profession!

I’m like; A fan of trolls. They light up my day and bring joy to the boards.

And Charles. Sorry to inform you bro. You’re wrong again. Better luck next time. Close but no cigar.

Is this the same realtor guy whom hung up on me all frustrated and said; I’m not going to get drawn into some long annoying conversation about value… True story.

It’s always the decibels on percentages that confuse the jr math associates.

That and sometimes I swear my calculator is haunted.

Good catch! I noticed the math error immediately because I am an appraiser and accustomed to using math daily. You would think the writer of this article would know better.

Charles is obviously not an appraiser.

Don’t feed the trolls people.

How many appraisers do you know? I know hundreds and they will all admit when they are wrong or made an error. The key is, you have to have factual and supportable evidence, not just emotional evidence. Keep in mind when we perform appraisals that it is for fair market value which has a long list of what this definition includes.

But this company that wrote this research is an AMC trying to promote their AVM product which has no regulatory parameters or rules to follow. They get to basically say “trust us, it’s proprietary” and nobody can see if the algorithm is violating fair lending rules or even follows basic appraisal theory.

This AMC is also likely price gouging consumers under the TRID-Respa disclosure rules by charging the consumer $600+ and then paying the appraiser $250-300 after sending it to bid to 200+ appraisers and taking the cheapest and fastest one. Quality is not an AMCs concern and these automated checks only look for certain boxes to be filled.

Hell I just caught a file FNMA passed off as a 2 on the DU/CU score as low risk. But, because I was familiar with the market I knew the land adjustments were incorrect and the appraiser manipulated the adjustments to pass DU/CU. Needless to say that is at their state board now showing the Secondary Market report vs the internal corrected report.

Then you probably believe the same of doctors, lawyers, accountants,…..

What a silly statement! Speaking in absolutes about an entire profession is ignorant, as well as not knowing that the appraiser is LITERALLY paid to be the expert. A true expert acknowledges the possibility of mistakes and the necessity of correcting them.

Thank you both. I actually asked mod for an edit down to a more simple statement.

People outside of this immediate forum can seek out and read the comments if they want.

I’ll remain convinced the effort is a cover over type of deal, only pretending to care about the issues for PR purposes.

The CFPB’s safe harbor rule caused the amc problem to continue.

Now they’re going to magically correct their own error?

Dare to dream.

The editing process to 5k characters was pretty rough. lol. I made a point of keeping the wire fraud topic matter in there. Among the more important suggestions to be sure.

Thank you both. Have a good one.

Thank you.

It looks like you covered everything, including my wire fraud observation. We (appraisers) owe you a bottle of mescaline….only to be used when you have two to four weeks off to prepare for reentry.

Pat that’s in the second link from the post above. Just scroll down to the amc’s terms and conditions. It’s extra ordinarily easy to read and prove offensive amc policies. They literally all have the same non disclosure policies.
https://appraisersblogs.com/amc-engagement-letter-appraisers-do-not-include-your-invoice/

It’s no secret and the amc industry has gotten away with this unearned fee junk fee rake billing scheme for twenty years already.

New york is the only state to legally require the appraisers to submit invoices, passed by way of their legislative process. But nowhere else.

So. They. Could. Make. Billions. Of. Dollars. Raking. Junk. Fees. Without. Consumers. Lenders. Or. Regulators. Knowing.

FHFA has set policies which condition FNMA executive compensation on their ability to use appraisers less rather then more. They get corporate windfall bonus compensation packages for doing so.

The CFPB investigation into junk fees is most likely just part of a cleanup effort to answer possible accountability and paper trails.

In preparation for appraisal automation where they can legally rake the entire fee and there will be no human appraisers to complain, be in total control of all automated value products and subsequent lending decision outcomes.

How do I get a copy of this letter?
They are so damn stupid
Don’t include your invoice
BUT in NY you are REQUIRED to?!?!?

Thanks, appreciated.

This was the online video about mescal production that sparked my interest. Super interesting, traditional production methods.16 min. How traditional mescal is harvested and produced locally.
https://www.msn.com/en-in/video/other/mezcal-is-now-the-fastest-growing-liquor-in-the-us-why-aren-t-mexican-producers-cashing-in/vi-BB1kSwkn?ocid=FinanceShimLayer

Very solid. I will send this as far and wide as I can.

I owe you a bottle of Mescal.

I’ve often written up reports half asleep or sometimes hung over but do not recall hallucinogens as helping defensible appraisal reports. That’s a good one.

I wrote the CFPB letter on amc billing. Finally made the time.

They won’t listen. But at least we tried.