AMC Engagement Letter: Appraisers Do Not Include Your Invoice
File the complaint against the AMC yourself OR Forward the engagement letter to VaCAP to file on your behalf.
At the recent Virginia Appraisal Board Meeting on Wednesday June 28th, a discussion occurred about Appraisal Management Companies prohibiting appraisers from including their invoices with the appraisal report. The overall consensus of the Board Members was this practice could be a violation of Virginia Appraisal Management Company Statute § 54.1-2022 B.
The Board members encouraged documentation of this practice be forwarded to DPOR as complaints against the Appraisal Management Company. All complaints received must have been for suspected violations within the past 36 months.
We understand many appraisers do not want to pursue a complaint against an AMC for fear of retaliation. So here are two options:
File the complaint against the AMC yourself.
or
Forward the engagement letter to VaCAP to file on your behalf.
To file a complaint yourself, click here to go to DPOR’s website and file online.
To forward to VaCAP, send us an email with the engagement letter here. Feel free to redact any personal identifiable information you feel is necessary as long as the terms and conditions of the engagement letter are visible along with the Appraisal Management Company name. Your personal information will not be forwarded to DPOR, only the engagement letter. Your personal information will be held in strict confidence.
Time to pay your Dues. VaCAP has not collected membership dues since the pandemic started. We have now reactivated the membership and renewal application. Please renew your membership here. VaCAP is 100%% volunteers and your participation in addition to yearly $84 dues is always appreciated!
Than you for supporting VaCAP!
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I wish Washington State had similar views. I would love to flush the crappy AMC’s out. The ones that offer a service and transparency I suppose could stay.
Pepsi challenge; Name one single amc who is transparent with their billing, and bills for the amc management service separately from the appraiser.
Myself and about forty thousand other currently licensed appraisers would jump right back into amc work if that was the case. Our absence proves there is no such thing as a transparent amc when it comes to ethical, fair, and transparent billing processes. The other hundred thousand appraisers whom left this industry due to an ongoing train of amc abuses likewise proves the same point. I wrote a rather lengthy summary of the appraisal industry over the past decade or so, regarding this exact topic matter of amc’s influence and detriment to these previously vital lending related companies.
https://appraisersblogs.com/fighting-tooth-n-nail-4-consumer-protection-n-the-appraisal-industry/#comment-38688
Thank you for your efforts. NCREAA and NCPAC proposed a similar idea to our board 6 years ago. It was discussed and “tabled” for review. Disappeared of course. Good luck and please keep up the good fight as things get more desperate by the day.
Perhaps consider an audit or some action compelling every amc in the state to submit an official policy regarding these issues to the board, alongside a random survey for all appraisers if they’ve experienced this restrictive activity?
I spent a half hour combing through old workfile data, and will post a series of screen clips from various previous amc engagement terms. These are activities which are standard engagement actions for the majority of amc companies in this country. Any appraiser whom has worked with amcs in the past can simply recreate this effort. I’ll stop at ten examples. Please make note of the bold highlighted ones; DO NOT include. Thank you, a good effort, will look forward to follow up if possible. I labeled the images, also will post image title with each post.
ACT amc 2012
Corelogic, Qauntrix, 2010.
First American 2022 / from standard engagement panel onboarding document. Funny story, I had accidentally applied at an amc thinking this was a different type of company and was instantly approved, then asked to be removed the next day.
Landmark amc 2015
MAM 2015, Members Appraisal Management
NREIS 2008
Solidifi amc 2018
Streetlinks amc 2011
SWBC amc 2016 / Those guys kept forgetting to include counter offers with sales contracts, then agents and underwriters were all mad at me for not considering any counter offer as valid. Well I’d have to know about counter offers in the first place to consider their validity. Threw me under the bus multiple times. Geesh.
TSI 2010. This was interesting to include because initially all these amc’s had engagement terms demanding the appraiser keep their compensation secret from borrowers, lenders, or often times both. A consequence of improperly co mingled fees, free reign to rake junk fees undisclosed. And it’s been that way ever since.
O.k., I probably have many more than this, but additional examples are not necessary to prove the point. I’ll remain mystified why local boards and federal regulatory authorities have never thoroughly audited amc’s to examine their junk fee raking activity or otherwise somewhat consistent junk fee raking amounts. This is how appraisal management companies incentivized appraisers to engage in unethical activity. So many amc appraisers took a leg up over other licensed appraisers and drove so many tens of thousands of mortgage lending focused appraisers out of business. They provided an incentive to be the preferred amc order assignee, a thing of value provided to the amc, by reducing their appraisal fees, colluding to keep these fee distributions secret from borrowers and lenders alike. Consumers have never ever saved even a dollar based on the volume discount theory, because the amc’s pocket the difference. Amc’s clearly have a motivation to drive appraiser vendors fees down, drive consumers fees up, and pocket the difference. Now the amc companies have successfully found ways to ‘manage’ the appraiser out of the picture almost completely, except for a one tenth compensation desk assignment, accompanied by an even lower priced PDC property data collector. And guess who still will not save a dollar, and will continue to pay the equivalent of full service valuation fees…
Redacting personal information will not eliminate the possible treat. Per the client file number/and or loan number it is easy to track back to the appraiser who completed the appraisal. Am I wrong?
It is against the law to punish the appraiser not ordering any more from him/her, for other treason than quality issues (the reason must be told in writing to the appraiser), but it is another possible law suit(s) which can take years and a LOT OF MONEY. Am I wrong?
Per Dodd-Frank appraisers must be paid reasonable fee. We need to prove that most of the appraisers are not happy with the fee… and request more? (Let mortgage companies figuring out how.) Yes, AMC’s best interest is to find the cheapest appraiser, which is against Dodd-Frank (see above) and also Fannie Mae regulations: find the best appraiser for that particular property (Selling Guide). We have many angle and resources to stop the exploitations, but we need to stand up, together. If everyone alone tries to solve the problem, it will never be solved.
Attacks will keep coming from all over until this profession is gone.
Couldn’t agree more.
Any comments?