Fastapp AMC Alleged Violations of AIR
The following court documents in the case Naftali Horowitz v. [xxx], Fastapp AMC founder v. Fastapp AMC president, confirm what appraisers have been saying all along, that if you want high-volume AMC work, you have to lower your fees to 1980’s level, have 24 hour turn times, and, above all, be a number hitter.
Horowitz, Fastapp founder, filed a lawsuit in New York court on January 31, 2022 against defendant to, among other things, remove the defendant as an officer and director of the Company because, when he brought her on as shareholder in 2020, he claimed that she made certain false representations and promises that were never kept. Horowitz is an individual residing in Brooklyn, New York, and is the founder, and, at all relevant times, a 49% shareholder Fastapp. The defendant is an individual residing in Newport Beach, California, and, at all relevant times, a 51% shareholder of Fastapp.
The defendant is no longer the president of Fastapp.
Horowitz claimed that the defendant engaged in conduct constituting potential violations of the Appraiser Independence Requirements under the Dodd-Frank Act of 2010 (“Dodd-Frank Act”), including unlawfully seeking to influence an appraiser to encourage a targeted value to facilitate the making or pricing of the transaction in violation of 15 U.S.C. § 1639e(b)(3). (See copies of emails in Exhibit 3).
In one example of an alleged violation, Horowitz alleged that the defendant had been asked by a loan officer to fix a “low” appraisal: See copy of the email of the loan officer here and the alleged email response from Fastapp.
Horowitz claimed that he discovered other instances of defendant improperly communicating with mortgage brokers and appraisers in an effort to ensure and steering assignments to certain appraisers at the behest of mortgage brokers in clear violation of DoddFrank and AIR.
For example, on or about January 6, 2022, Fastapp received an order for an appraisal on a property located at 315 Toleman Rd Washingtonville NY 10992. The appraiser to whom the appraisal was assigned posted on the valuelink system that he could not “hit the number they are looking for” and that he was “going to back away”. On January 20, 2022, Burnstein advised [defendant] “Look what Kim just posted in this order”. [defendant] responded “UGHHHHHH, can we delete this?” Burnstein advised her that “Lol, I see you did it. Note that in the history you can still see that a comment was deleted.” [defendant] sent an email to Burnstein, using [defendant] personal non-company email “Can you delete the history?” The evidence submitted herewith conclusively demonstrates that Burstein and [defendant] deleted the comments in the system in order to cover their tracks (copies of the documents and emails demonstrating [defendant] and Burstein’s deletion of evidence of their wrongdoing is annexed hereto as Exhibit 4).
Here is one of the emails in that thread where an appraiser informed Fastapp that “I CANNOT HIT THE NUMBER…”: Email in Exhibit 4.
Defendant in her counterclaims denied Horowitz’ allegations and alleged:
In this business dispute between Fastapp’s only two directors and shareholders, [the defendant] and other officers at Fastapp uncovered that Horowitz is engaged in a widespread fraudulent scheme violating federal laws regulating appraisal management companies (“AMC”). AMCs exist pursuant to federal laws enacted in order to avoid lenders and brokers steering appraisals to specific appraisers in a quid pro quo pursuant to which the appraiser will appraise a property at a requested value in exchange for a large volume of appraisals. Yet this is exactly how Horowitz conducts his business: he directs thousands of appraisals to a small handful of appraisers who will appraise properties at values requested by Horowitz’s broker and lender clients. [Defendant] joined Fastapp in 2020 as a 51% shareholder and director, and with the aid of the Chief Operating Officer, Rachel Burstein (“Burstein”), came to learn that almost all of Horowitz’s business violates federal law.
The defendant stated she “recognized that Fastapp’s appraisers should not be trying to ‘hit the number they are looking for’.” She further stated: “Our Company does not condone anyone at Fastapp encouraging appraisers to target a number that brokers or lenders are looking for, and we advised [the appraiser] of the Company’s position in view of his comment.”
She alleged that after she joined Fastapp:
it began to become apparent to [the defendant] that Horowitz was not complying with appraisal independence standards. Instead, Horowitz would personally select one of a small number of his preferred appraisers for any given appraisal request… It thus became apparent to [the defendant] that Horowitz was engaged in a widespread scheme in violation of federal law by assigning appraisals to appraisers who would appraise values at requested values in exchange for order flow.
30. Pursuant to Appraisal Independence Requirements under the Dodd-Frank Act, AMC’s are not permitted to influence an appraiser to encourage a targeted value in order to facilitate the making or pricing of the transaction.
Defendant alleged:
“He directs thousands of appraisals to a small handful of appraisers who will appraise properties at values requested by Horowitz’s broker and lender clients…”
37. Horowitz, however, has steered over 3000 appraisals to two appraisers, Joel Wiesenfeld and Usher Klein, and paid them over $1.75 million. There is no lawful justification for Horowitz’s conduct. Instead, Horowitz is assigning appraisals to Wiesenfeld and Klein in a quid pro quo pursuant to which they will appraise properties at requested values in exchange for order flow…
Horowitz’s unlawful conduct has put Fastapp at risk of regulatory enforcement actions.”
Exhibit C Total Fees for Appraisers
Horowitz denied defendants’s allegations in his reply to the counterclaims. They reached a settlement a month later and the case was dismissed.
Postscript 2/8/2023
We were contacted by Fastapp former president claiming that publishing her name and email is a violation of DMCA, and to remove this article or at minimum remove her name and email. Even though all the information we published in this article are in public court filing, we decided to edit the article. We replaced her name with her former title at Fastapp (president). We also removed all the screenshots of emails but provided direct link to those emails in the exhibits with the court.
Postscript 2/9/2023
A second request was made by the defendant to remove the title “president” “as it insinuates that the current president” of Fastapp AMC did this. We edited the article and replaced “president” with “defendant”. Added the following commentary: “The defendant is no longer the president of Fastapp”. We were also asked to remove the name of the AMC, Fastapp, but decided against doing so.
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Anyone thinking FastApp is the only AMC playing this game is a fool. I can think of others who violate AIR on a regular basis. The only player POWERFUL enough to put a stop to this is the Appraiser. If appraisers do not play, AMCs have no business model and their doors are shuttered. Stand up for yourselves, appraisers. Stop hiding in the shadows looking for work to show up in your inbox. Stop pandering to the wants and intimidations promoted by some AMCs. Time to take your profession back.
Solidfi does this on a routine basis.
“The business plan written on a restaurant napkin.” Oh Canada.
Do their reps still troll on the AF?
Absolutely!!
Interesting, however there are no new revelations here. Separation from loan production is a pure myth, it never happens. If an amc is present or not makes no difference. The only model to prevent this sort of activity is round robin even distribution of orders to all appraisers on panel. If an appraiser is on a lender and/or amc’s panel, they should receive a fair share of work or they should not be an approved appraiser on panel. The faster an appraiser gets them done, the faster the appraiser is back in line for the next order. The model of appraisers needing to beg and appeal for more work or alternatively all work only going to the appraisers with best statistics or lowest fees is fundamentally flawed and quite frankly totally ridiculous and discriminatory.
This in the end is yet another example of how the tech companies as well as amc companies whom are also tech focused or use these order management systems, are willing accomplices to violations of existing regulatory guidelines and such. They cook all these tools in to give lenders total control and to give appraisers virtually none. If you talk to the tech people at these order management platform companies, they regurgitate compliance language while simultaneously stating they believe their job is to provide tools for amc’s and lenders to maintain this kind of leverage over appraiser vendors. Why don’t appraisers get to see these stats like some competition scenario or something, or know how many other appraisers fee quotes were sent to, or clearly see all other appraiser vendors fees, total order volume for the distributor? I could write two dozen articles with evidentiary reference, how such pressure is routinely applied, how common such unfair dealings are. The story built and was getting really exciting, then just like that, they settled and it was over.
Missing the ivpi proposal yet?
https://www.workingre.com/wp-content/uploads/2013/08/IVPI-Proposalfinal.pdf
The State of California is responsible for the fraud and deceit practiced by the licensed. The fear of the CA. DOJ. and the DREA. is committing a criminal act against the people.
Appraisers don’t count, because those two regulatory agencies swore allegiance to the STATE.
Our appraisal work is subject to scrutiny by law and our contract with our client. We as individuals may suffer ridicule and sarcasm when (if) we complain, and it takes lots of time to do other than BITCH.
This is not unusual conduct at all.
It’s the standard!
Lets not forget their are so called leaders in the appraisal field that coach AMC’s are the answer, and a churn and burn of 4 to 9 appraisals A DAY can be taught for a monthly subscription fee. Or the fact that most AMC’s are “appraiser owned”. Systemic racism in appraising, I think not, greedy and immoral bad apples, “do as I say and not as I do”, unfortunately yes.
Seek the truth, find the truth, tell others about the truth, and above all else, don’t put profits before principles.
Will someone tell me WHAT is fast enough?!
One second faster then the next guy. And if you asking, one penny cheaper.
Seek the truth.
I currently have a bid that is sitting in MN for 5 hrs. I am sure the lender wants to see if someone will bid $50 lower or 1 day faster. In that 5 hrs I could have had the appointment set and been well into my preliminary research. These are the same people that say the appraisers take too long. I would not be surprised if someone will do it for $200 in 24 hrs. 3 sales and 2 listings in a very small market. Have at it skippy.
‘I currently have a bid.’
I have identified your primary problem.
Respectable fair dealing clients send appraisers orders with up front fees.
I’ve been getting anywhere from $550 minimum to $950 stated up front fees, assigned to me and me alone, for many years now.
Find better clients. If they can’t figure out what a fair fee is by now, we can’t help them. They already know the borrowers appraisal services quote. Everything after that which does not reduce costs to borrowers is just predatory unethical assignment practice. They’re not shopping to save any money. They are shopping to apply pressure to appraisers to play ball and advocate for more amc profit, or be excluded from the workforce.
This is not an AMC this is a lender that uses Mercury Network. Up until 7 months ago my lender clients paid $600 – $800 per report. These clients have all disappeared now that the rates went up. I worked with one of them for 12 years now poof they are all gone. In 40 years, I have never completed an appraisal for and AMC. I am getting ready to retire.
Darn Mercury. But by keeping the ‘accept bids’ option checked, an appraiser also loses all control to auto block the thousand amc’s whom also use that system, whom will also shotgun spam order requests to off panel appraisers. Mercury absolutely refuses to give appraisers a work with yes/no option. Because they tried that for like less than a week a long time ago. Before amc’s had gained as much market share. Every single appraiser immediately said no and Mercury removed the option. In the days of Appraisal Advisor, when there was still hope and good people willing to do something.
Flash forward to recent times. The amc’s grew wise to the minuscule additional helpful tools Mercury provided appraisers, like the ability to set a client identified on your client panel list to vacation for a full year to keep them from bothering you, and the addition of the accept bids yes no option which is applied universally to all of the appraisers clients at once. They moved to Scope, Value Link, and beyond, at least the more predatory ones did. Scope is light years behind Mercury in providing appraisers even simple helpful tools to protect ourselves from exploitative amc practices.
Riddle me this, riddle me that, why did Mercury personnel purposefully decide that appraisers could have yes/no options for accepting bids in general, but somehow felt it was not appropriate or necessary to allow that option to be applied to individual clients or off panel appraiser try out type of requests? I’ve missed out on many an opportunity for higher paying by quote request orders and possible new client connections because I had to keep that option set to no. Thankfully I never actually needed them and at this time that’s pretty pointless to pursue.
Mercury was allowing off panel amc’s to email me bid requests four times a day or more and I was powerless to stop it. I demanded they be put on my client list so I could set them to vacation, as they were essentially treating me like a panel appraiser, sending me non stop requests, no relief. Mercury systems do not allow fee setting per individual client, errantly presuming some general state where there is never SOW or complexity difficulty which is attributable to different clients and different client types. They don’t allow appraisers specific control over off panel requests. They provide free unlimited access for amc’s to spam off panel appraisers, with no helpful indication or signal how many other appraisers the request was sent to or how many other appraisers may have already responded. They no longer help appraisers connect with non amc companies, as previous efforts to do so resulted in basically the entire library of active appraisers barraging non amc lenders with an overwhelming volume of panel requests. They no longer market the company as a safe haven from amc’s, but rather now that the company is owned in part by a corporation whom ran arguably the one of the most exploitative notorious appraisal management company ever conceived, Mercury consistently advocates for amc’s on it’s public facing material instead.
Whatever dream Dave Biggers once pretended to promote is gone. It’s a complete sell out with our premier companies ran by our people which we explicitly trusted, selling all of us out. If Brookings tried this junk 12 years ago, our primary software provider alongside our insurance providers as well as our appraisal industry specific trade groups would have mobilized immediately and publicly in defense of appraisers and against exploitative practices. Instead we get corporate interest advocates masquerading as appraisal industry representatives, both inside our own organizations, the amc trade groups, and beyond. Goes to show you the poor and diminished state of appraisal industry ‘management’ today.
When do we get a say? When do we get a vote? New leadership is necessary. Did you read the AI update email, that the lead guy was cozying up at Brookings Institute, watching movies with the crew? It’s a non stop apology tour for these people, counter productive irrational approaches, no apparent independent representation ability even present. They do not even understand what the word no is, much less how to use it. We could do better.
Rant over. The lawnmower has now entered the chat.
I liked Dave Biggers; he convinced me the plagiarizing was dishonest and reflected badly of appraisers who practiced it.
Dave was awesome, until he wasn’t. Straight Judas. He even forced his son to Abandon the Appraisal Advisor website, which would have been the premier source of appraiser whistleblower activity for corrupt amc group practices. There was so much disclosure in just the 4-6 weeks the site was actually operational, they did not know how to handle it. This website you are on now is the closest you’ll get. Wished I would have saved screenshots and such. Down the memory hole it went, all of it. There are no whistleblower protections, not for appraisers when dealing with amc’s. Community Partnership Program, what a joke.
https://blogs.alamode.com/appraisal-advisor-closure-new-community-partnership-program/
Forward this to the Comptroller? CFPB certainly won’t do anything.
https://appraisersblogs.com/appraisal/occ-bulletin-regarding-amcs-lenders-and-appraisal-advisor/
https://appraisersblogs.com/appraisal/appraisal-advisor-a-real-estate-appraisal-technology-company-launches-nationwide/
https://appraisersblogs.com/appraisal/appraisal-advisor-now-completely-free-for-appraisers/
https://appraisersblogs.com/appraisal/appraisal-advisor-ceases-operations/
https://www.businesswire.com/news/home/20130416005236/en/Appraisal-Advisor-a-Real-Estate-Appraisal-Technology-Company-Launches-Nationwide
https://web.archive.org/web/20230000000000*/www.appraisaladvisor.com
Learn to use the Way Back Machine.
I rarely bid. There is only one AMC I do bids for because many times they will just give it to me right away without playing games and the first time I quoted $550 and they gave it to me for $600 because it was their standard fee. Small things like that generate goodwill, at least with me.
I think I bid a relo. for them. The bid included extraordinary info, alerting them about The Hobby Farm, including water shares, fruit on the trees, managing and marketing contracts.
They voluntarily paid a fee & cancelled the job. Stating that the situation was too complex.
There are several companies with conscious out there doing a good business.
Even crazier is when two-three weeks later you get some revision on something you already addressed…they are in a rush to get you to complete the report but in no rush for anything else. 2-3 weeks to barely look at it and waste your time.
“Horowitz, however, has steered over 3000 appraisals to two appraisers, Joel Wiesenfeld and Usher Klein, ” Over what period of time? Does each have 5 trainees?
All great questions. One of the goals in creating the CU system was to track systemic appraisal deficiency, was it not? They really folded to the amc industries interests, it would appear. My bet is on outsourced typing services. From an individual appraisers perspective, why take the risk with your license and liability. But then again, many appear to be besting the regulatory model, winning on the risk vs reward consideration.
It’s still a departure from guidance stated numerous times in the federal registry, that appraisers should be selected on merit not fee turn time or other strictly performance based metrics. It’s hard to believe those few appraisers really had that much better skills and qualifications to justify such severe imbalance in total order distribution trends. Then tag on the fact that volume appraisers will often turn down the most complex work, as they can’t swing it for their typical discounts and it’s less profitable, so they pass complex and time consuming requests to the other appraisers. It defies logic that the appraisers whom get the least volume are also commonly tasked with the most complex work, because the discounters took the lions share of simple more beneficial to the appraiser orders upstream of them. This is yet another reason why blind rotational is better, appraisers should benefit from the random factor, sometimes orders are easy, sometimes they’re more difficult, but most of them should be completed for a relatively uniform fee. The amc’s continue to exploit the appraisers individual vendor nature, refusing to issue a uniform fee for all panel members in any given location. Rather, the amc will opportunistically fee rake and actually incentivizes and encourages unethical engagements in terms of appraisers ability and willingness to provide well rounded service. Cost plus would solve that, separate billing for distinctly separate services. Amc’s should charge their own uniform handling fee and be done with this nonsense, then we could work with them again, the amc industry would instantly have 60,000 more appraisers to choose from and appraisers would not longer be excluded from the workforce for simply demanding ethical engagements. The irony.
There is nothing wrong with ‘hitting the number’, if the number presented such as in a sales situation is plausible. The market is after all, set by the participators. Some appraisers probably get lost in the weeds with their own analysis methods. The priority should be under optimal conditions with optimal representation. Which is why open doors and lax qualifications for refinances causes valuation products to be somewhat less reliable for refinance as compared to true open market exposure tests such as sales situations. These can be difficult to express concepts to people whom don’t understand the difference between price and value. Under these new systems it can be better to simply decline orders in which one can not see an avenue to success. It’s also a test of the brokerage persons ethic and the distributors ethic, if they will continue to shop and shop, or if they will provide that honest feedback; that we can’t even find an appraiser to take this, because we’ve had a dozen appraisers telling us this does not comp out, that sort of thing.
Obviously the amc is willing to compromise integrity to increase profits, if those appraisers were taking work at lower fees than the majority body of other appraisers on panel. This is the exact way amc’s exploit the process because rather than surveying fees to understand what the lowest fee the majority of appraisers would accept (the peer standard), the amc’s instead use individual fee setting as a means to deny the peer standard and instead funnel the lions share to the most extreme discounters. It’s one thing to select a particular vendor to save a dollar, it’s quite another when cost savings are not returned to borrowing consumers.
“There is nothing wrong with ‘hitting the number’, if the number presented such as in a sales situation is plausible. The market is after all, set by the participators.”
Just make sure it is reflected in your value definition that it is plausible and not the most probable.
The ethical are completing a product that is not wanted by AMCs. So appraisers are trapped between their ethics and being out of work, and then when the market collapses the industry as a whole is blamed because the lenders choose the bad apples.
Why Not hit the numbers. In many of our jobs an offer has been made and we have that knowledge. The form 1004 has a place to express it: (My value opinion has been influenced by the offer made).
Before the scarry rules were published by the states some of us made up our own form, and many Freeley gave value advice to good clients.: I informed my client the lender that the property owner owed the property next door, or tell him a divorce was pending, or that a government agency was thinking about a taking.
I also shotgunned values, glancing at CMCD. sheets and opining that 5-3-2, with a single car attached were selling for around $15,000 – $17,000.
I built my business that way away back then.
Back in the day, refinance figures were formed from comp searches not the other way around.
To clarify, probable means it’s not just an outlier, but within standard benchmarks to value for the market segment at hand. Responsible agents means an easy path for the appraiser, usually. Aggressive predatory agency means the appraiser may not be able to bring that home.
Do you remember the appraisers are biased accusation specifically talking about how more deals are killed by appraisers in minority tracts… Who’s not adding one plus one here, that the probability of agent misrepresentation is higher in these areas and the appraiser may be the only person protecting minority borrowers from being over leveraged and paying too much.
Not everyone is qualified to be a competent data analysts. Andre, from Brookings, talking to you. Equity to Andre means being on top, and everyone else subservient to his special interest projects.
“Back in the day”. Lenders wanted to lien all of the properties available, hence the vacant lot, the rental, or the 47 chevy. In the most recent times tract lenders require a builder to put in more money, because the unfinished development did not offer enough security.
Our client was NOT the barrower. Many banks and lenders hired part time tellers and officers for protection and security. Appraisers may have to EVALUATE the milking heard or and the haystack.
Remember the motel just outside of Reno the IRS had to repossess & operate several years ago. All kinds of chattels were under contract.
This is why when appraisers come in at market value they sometimes get sued for discrimination. Another desperate appraiser will come in over market making borrower assume first appraisal was too low and biased.
For the discrimination lawsuits how many of these 2nd higher appraisals have you seen? How do we even know they exist or were even done by an appraiser unless a loan was made. I imagine a second appraisal was completed in the Tates (Marin City) case because it was used for a loan. Maybe a quick CMA, BPO, AVM, or fabricated entirely in some cases.
The saving grace here appears to be that when the numbers are lower than their expectations, they do not rely on the appraisal, but rather just get another one. Several times now we’ve seen the judges disposition that ‘since they did not rely on that appraisal for a loan.’
Them krooks is allways smarter than the Indians, but Pocahontas’s will win in the long run.
This is why when appraisers come in at market value they sometimes get sued for discrimination. Another desperate appraiser will come in over market making borrower assume first appraisal was too low and biased.
The civil complaint may have been settled but the AIR violations need be addressed.
Seems like a He Said V She Said situation….albeit w/o any marriage. lol
FYI: she is still an active California appraiser as of today, Lic No. AR 028229 (taken from public records).
There are untold numbers of AMC’s and appraisers that should be brought up on charges.
For a good quality appraiser, doing FIVE quality appraisal reports a week is a challenge.
When I hear someone say they are doing 1,500 a year (3,000 appraisal reports divided by TWO appraisers; that’s 4.21 appraisal reports per day, non-stop, no days off)… something is wrong.
Who cares. What’s the punishment? Nothing.
Isn’t that a great question? Why aren’t they being investigated by the regulatory commission as well as setting up an Appraisal Management Oversight Investigation.
I filed complaints with WASDOL, CFPB, NAR and anyone else in the Torin pole for an AIR violation with a LO office that stated I was the appraiser they were having difficulties with. I filed a complaint with lender and AMCs compliance officers. Not a single response from any of the agencies that I filed a complaint with. No one cares. No one, unless you’re Wells Fargo and they can fine someone hundreds of millions. No one cares about the small cases unless it is racial bias, only then do they care because it is pushing the flavor of the month.
Should be considered mortgage fraud!!!!
Just further proof there is no oversight by the regulatory bodies of the AMC’s unlike the appraisers themselves who are now accused of bias and racism… just another nail in the coffin.
It defies logic. APPRAISAL MANAGEMENT is their exact title. Did Elizabeth Warren grill the CEO of Wells Fargo, or did she grill the regular employees?
Someone please start tracking the frequency by which appraisers are biased accusations are sourced from. It appears nearly all of them come via the appraisal management company realm.
Exactly! I hate amcs
We the Appraisers need to get rid of that middle man, the AMC. It’s worthless, didn’t change anything but take some of our money.
There is no longer ANY independence as if there ever was because most AMC’s are owned by the banks!!!
If the banks don’t own them, the AMCs certainly are their lackeys!!!!
It’s easier to give instructions/demands to a central entity than try to force a dozen appraisers to do their bidding.
Now that this has seen the light of day why isn’t the CFPB investigating the alligations?
Not enough money for them to get out of bed for it.
Oh hell, fine, let’s run through this again. The CFPB is the entity that changed Customary AND Reasonable, to customary OR reasonable, and created the safe harbor rule which basically nullified the original spirit and intention of the C&R rule in the first place, basically sanctioning the wholesale exploitation of the appraisers by the amc industry. For good measure they approved additional redaction which removed the original $10k per violation instance, and repeat DAILY fines of $20k, per continued violation instance, for non compliance with fair appraiser compensation, as those fine structures were set in place to guarantee compliance and force amc’s to bill additional for their services, or be wiped out by fines. Mercury systems at the time, when it was still a sister company to Alamode, before the Dave Biggers industry betrayal, published a C&R survey from their systems which basically would have functioned as an established fee survey or minimum amount any amc could have compensated appraisers or risk those fines.
For the newer appraisers whom may be here, the DoddFrank RegZ rule on Appraiser Independence, C&R compensation had specifically prescribed a condition that appraisers must be compensated by an amc, an equivalent amount as if an amc was not present, thereby forcing amc’s to bill for their services separately or compel the lenders to charge consumers more or cover the amc costs on the lender side. It was a death sentence to stop the predatory amc industry before it gained any more traction. TAVMA the amc trade group at the time worked with their partner lenders, ran lobbyists to the CFPB, and just like that the updated HUD consumer fee disclosure forms did not contain a separate line item for amc fee amount, but rather improplerly co mingled the amc and appraisers fees, and the C&R fictitious safe harbor appraiser compensation language was set into the official DF RegZ explanation pages. Hence;
Please advise when the fictitious CFPB C&R safe harbor interpretation will be rescinded. One of the big shots on AF used to constantly post that, I think it was Mike Kennedy, but not sure, been a decade now. And other notable tag lines such as; Distinctly different fees for distinctly different services.
https://www.consumerfinance.gov/rules-policy/regulations/1026/42/
Scroll down, I gave you the top of link, if you scroll down the link address changes in real time while you scroll, if you want to reference one part specifically. Also this Fast App amc documented behavior is a violation of several provisions here. But don’t look for the CFPB to solve anything, there were several hundred thousand appraisers and the industry when CFPB also sold us out, and this industry literally shed one hundred thousand appraisers after their corrupt interpretations which went against the spirit of Reg Z AIR rules. So many worked into the updated legislation in the first place. The thousands of appraises who put in so much effort were devastated. That’s like a backstory for the Retired Appraiser guy who posts here, he was like somehow involved in advocacy to save the profession from all the exploitation, and thousand of other disgruntled former and current appraisers like him. That’s why it’s such a supreme disappointment and admission of absolute ignorance and improper ethic about their own industry, when appraisers mention they’re still willing to work with amc’s. In turn, those amc appraisers place themselves in a defacto position that they agree that these amc companies have standing and merit to exclude the rest of us from the workforce. The most unethical appraisers claimed the lions share of orders and that’s all she wrote. That’s evident here too, the few guys got millions in order compensation, everyone else rode the bench. The appraisal coach has entered the chat.
Missing the IVPI yet? I’ll never quit posting this. Basically it would have been a VA panel type setup, for the entire GSE systems set. I was talking to nationally recognized appraisers to get myself on the inside to be part of this emerging institutions daily operations team, but it never materialized, sadly. That’s why I’ll never let it go, those criminal lying scumbags with the amc trade groups sold one thing but delivered another. At one point I was approved down the entire TAVMA list, and never once identified an amc that complied with C&R as intended, nor did I find a single one which behaved in an ethical manner. The AIR violations are just daily normal occurances for these companies. I have two full legal drawers and a lengthy digital folder record to prove it. But who to prove it to? TAF sold out to the amc trade groups long ago. We are not just under represented. We are plainly not represented at all. It’s a pay to play system and every appraiser has to determine their level of engagement. This is why I still to this day only pay basic licensing and CE fees, and bare bones software costs. The TAF group and their subsidiaries is a big club which I am not a part of, nor do I want to be. If AI offered me a full fledged membership for free, I would refuse it. Who would want to be associated with a member group whom betrayed that much trust, co opted their members to antagonistic interests, and profiteered the whole way through. Cosmic cobra ain’t even the half of it, but at least someone noticed what has been going on this whole time. Don’t get me started on the Altera group, or we may have to start talking about how they all owe us reperations, if they actually believed in equity, which they do not. These people have absolutely no problem nor inhibition about throwing individually licensed appraisers whom are outside of these groups under the bus and to the dogs of state agencies. Know where you are at, take it slow, do not outsource, and remember all it takes is one single time. Stay under the radar, it’s all you can do unless some sort of larger movement brings actual industry corrections towards better ethic. Sadly we’re going the wrong direction with current TAF leadership, having milk and cookies at Brookings Instittue and hiring the same lawyers who sue their own appraisers, all funded on the taxpayers and member dues dimes. Whatever with the amc’s, they’re just instant out of the box telecom companies, dime a dozen and I’m not paying for them, that’s the lenders responsibility as the lender hired them. Until that correction is made to a cost plus system, we will continue to refuse service.
https://www.workingre.com/wp-content/uploads/2013/08/IVPI-Proposalfinal.pdf
Related. Appraisers need to get educated, adhere to a better ethic, or just quit already. Won’t miss them.
https://appraisalnewsonline.typepad.com/appraisal_news_for_real_e/amc_appraisal_management/page/2/
https://appraisalnewsonline.typepad.com/files/the-amc-full-fee-hypothesis—jeff-schurman.pdf
Two posts, two example pieces per the above post. Thank you.
Second image. Mentions the fines.
From Dave Biggers emails to appraisers, sent 10/19/2010 email titled: “Customary and Reasonable” fee regulations. Check your email history if it goes back that far.
Suntender valuations, they are clowns that do the same thing. In 6 years I’ve gotten one order. Regularly bid and never get it. Last week I bid 250 on a 1025 with 3 day turntime. I got it. Then I emailed them sorry for the typo, my 3 fam fee is 750 and I immediately got an email the order was canceled and to not contact the borrower or discuss fees with anyone. Hahah. Shocked I wasn’t.
Call the borrower and ask what they are paying. The a**holes are NOT your client!!’
Identification and recognition of YOUR client is critical by Legislation and law.
all Amc are corrupt all they want is low fees and hit a number don’t be so naïve and think differently
Thank you for sharing a common experience of appraisers. This happens all over Utah. I call it the criminal cartel financial system that has been established for the thirty years I have been in business. Large credit unions, savings and loans, banks and AMC’s are playing with the same playbook. The board of realtors and lenders are in on it to further sealing the entrenchment of criminality. The powers that be in the regulatory sphere are on the same team so the defrauding of the public continues.
https://www.youtube.com/@PatriotRadioNewsHour/videos
“The powers that be”…….
Try my brand.