AMC Fee Impact on Appraisal Fee
While the borrower was charged $695 for the appraisal, the appraiser was only paid $301. The AMC fee was $394.
We often hear complaints from GSEs and lenders that appraisal fees are too high, hence the push for modernization. Yet they fail to acknowledge that this is due to an overly bloated middleman – the appraisal management company (AMC).
As a consumer, you should be aware of the potential for being fleeced on appraisal fees. It’s possible that you could be paying more than double what the appraiser is receiving for actually doing the work, with the excess going to an undisclosed third party.
AMCs are often contracted by lenders to manage the assignment of appraisals. Unfortunately, these companies can add excessive surcharges onto the final bills given to consumers without disclosing them in any way. This means that unsuspecting borrowers could end up overpaying significantly without even knowing it!
Take this example where the AMC, Solidifi, is overcharging the borrower. While the borrower was charged $695 for the appraisal, the appraiser was only paid $301. The AMC fee was $394. Solidifi made $394 to simply manage the order.
AMCs often seek to hide the amount of their add-ons by prohibiting appraisers from attaching their invoices to the appraisal report the consumer receives. And oftentimes, the consumer blames the appraiser for the high fee being charged, unaware that much of it is going into the AMCs’ pockets.
There is no other industry where paper-pushers make more money than actual experts. Yet somehow these same experts get blamed for being “too costly”. It is unacceptable for any industry or profession to be treated in such an inequitable manner, with those who have expertise not receiving proper compensation while paper-pushers receive higher paychecks.
It’s important for the consumer to do their due diligence when it comes to understanding exactly who they are dealing with throughout their real estate transaction process – especially when it comes to appraisals and hidden fees! Consumers need to ask their lender questions about how much they pay individual appraisers versus how much is charged on top of those fees.
- FHFA’s Appraisal Waivers Expansion - October 29, 2024
- Lack of Evidence, Appraiser Challenges Discrimination Claims - October 24, 2024
- NFHA’s False Narrative Undermines the Appraisal Industry - October 18, 2024
Looks like the curtain is being pulled all the way back on the wizard these days. It’s time for all appraisers to see this, expose this, and stop cowering in your basements. This is OUR INDUSTRY. It’s time that we make that clear to the ringmasters who think they are in control of our independence. CONSUMER PROTECTION is at great risk. We are the gatekeepers. It’s way past time to ignore these issues.
You guys have had 14 years to solve your little problem, yet you have never lifted a finger to help yourselves. Do you deserve anyone”s sympathy? No, but most homeowners and. Ex appraisers would gladly offer you some cheese to have with your WHINE. God helps those who help themselves.
Boy, that was helpful
That guy is a troll that probably retired long before AMC”S poisoned the well. Gotta love those backseat driver opinions.
I knew you’d be along to crap in this thread.
Maybe you should find a knitting forum or coin collecting forum to go haunt, since you’re retired and all.
I provided you with a solution to the problem Scotty. Read on. Unfortunately, the solution requires work from appraisers (something I have yet to see for the last 14 years). If you wish to save what’s left of this JOB get off of your butt and put in the work.
Mr RA. I just remember what a man once told me-“when your not swimming in the ocean its easy to give advice on dealing with sharks”. Get back in the game or go away.
Everyone get ready to donate
The statement God helps those who help themselves is not even in the Bible and of poor mind set. It’s not about self gain.
You aren’t saying something that is untrue, that’s certain
This issue now goes well beyond the AMC scheme and overall is worse today than any other time in history. Meaning, even when lenders don’t use an AMC (say the Mercury Network) the recent push to bid out the appraisal creates a direct profit stream for the lenders (no AMC middleman, excuse me middleperson). If the borrower pays $695, and the appraisal is bid out for $300, its the lender who directly profits from the spread. I can’t find my comments, but I brought this to light some months back.
Seek the truth.
The amc’s created a new industry standard. This is referenced in some of the older Dave Biggers newsletters I posted below. One of the reform points a decade or so ago was to change billing disclosure language from; ‘Appraisers fee’, to ‘Valuation services fee’. So yeah, now everyone can incorporate routine appraisal service management into the consumers valuation services fee, regardless of specific company type. We need a clear separation of billing correction in consumer disclosures. Managing the appraisal after completing should not be incorporated and co mingled with the actual cost of completing the appraisal.
Especially egregious because the valuation services fee could incorporate not just one, or two, or three, but four or more companies total billable amounts. The appraiser, the amc company, the pdc the amc hired supportive services, the tech companies providing service to facilitate the ‘management’, the processing, the list is endless. They can pad the appraisal fee to the moon and nobody would be the wiser.
Clearly these are deceptive practices not in alignment with the spirit of billing transparency to benefit consumers, which was the reason consumers costs fee disclosures are there in the first place. But appraisal management companies, being so damned special and exceptional, irreplaceable in the process even though they don’t actually provide anything of value except offshoring costs for lenders to increase profits, the billing transparency rules do not apply to amc’s. The amc’s drove over a hundred thousand sole propretor small business persons right off the map, nobody in FHFA, FNMA, HUD, or Freddie stood up for the small business person. VA was the only group involved with GSE’s whom protected appraisers. Appraisers own trade groups became co opted by the amc industry, and failed in their duty of care to their own members as well.
Missing the IVPI proposal yet?
https://www.workingre.com/wp-content/uploads/2013/08/IVPI-Proposalfinal.pdf
That’s why every Appraiser should ban Solidify. Just do it. Stop accepting crap fees. Simple , if they can’t get an assignment filled, they raise your fee!!!!
We can’t boycott twice. lol. CU system managers should post clear information how many appraisers are even working for amc’s. Because we know that is a very small portion of the larger appraiser community. That would illustrate how the new PDC program is so errantly conceived and represents a clear restraint of trade issue where the majority of requests would be funneled to a clear minority of available working appraisers. It was my understanding based on the white paper a few years back that over half of all appraisers refuse GSE work in general, and of the half that did complete GSE work, over half of those appraisers were never associated with having completed an amc assignment which ended up in the CU systems. Which means only one in four appraisers are willing to work with amc’s.
They know very well there is a skewed ratio that a select few appraisers are completing the majority of amc assignments, and that figure is far less than a fourth of all licensed appraisers. That one in four number also included appraisers whom may have only completed a few singles for amc’s which flowed through CU system, but likely did not complete many. It is highly likely that less than one in ten appraisers are willing to complete volume for appraisal management companies. But if they had to acknowledge and publish these factual data points, the narrative revolving around the supposed need for appraisal modernization reforms would be discredited. Responsible appraisal industry regulatory oversight is an illusion. The GSE managers have now switched to forming narratives and developing products in favor of preferred special interest groups. FOIA requests for CU system data on this matter is warranted. Clearly without a doubt, the CU system managers are not being transparent. By refusing to publish this data they are complicit in assisting amc companies in deceptive trade practices which unfairly restrict the majority of licensed appraisers participation in GSE assignments.
I once asked the regional manager why they were taking half the fee for basically doing nothing more than sending an email. There response was that when it’s busy appraisers get a bigger split. Now that it’s slower they are trying to get it back. Sigh. I fired them.
Sadly, the ethical rules which guide appraisers, do not apply to appraisal management company workers themselves. My vote is for individual licensing for every single amc employee. It’s time that those ‘managing’ ethical professionals were tasked with having some ethical requirements themselves.
They opportunistically apply the principal of substitution to rake more of the appraisers fee, while refusing to ever return cost savings from reduced appraisal costs, back to the consumer. With amc’s, consumers never save a dime. Junk fee billing rules do not apply to appraisal management companies.
The moment they OK’d PDC’ I knew it was time to move on. Instead of being a conduit post HVCC, the AMC’s found ways to fleece us & the borrowers.
False narrative – nobody is providing product in the $300 range. Indeed, AMC’s but more so lenders are only interested in appraisal cost, they are fighting a losing battle.
I am told by an appraiser friend that AMCs are receiving bids for many, if not most jobs at $275 to $300 since the slowdown, here in SoCal. While I can sympathize with appraisers who must feed their families, it is clear we are shooting ourselves in the foot by fighting with each other to be the lowest bidder. It IS happening. Thankfully, I’ll not be participating.
Incorrect. There are appraisers who are completing appraisals for 1980s fees. $300 and below for a URAR.
In doing reviews where appraisers have indicated their split within the body of the report (FHA), I can confirm Donna that fees in San Diego are often in the $250 to $300 range.
Seek the truth.
Dave, the newbs hang out at Appraisal/Reddit. The nonsense one can read over there. There is a very real possibility of instantly losing IQ points upon joining. I would not be surprised if the moderators are somehow tied in with the appraisal management industry. But that’s where they hang, the amc appraisers whom coordinate on discounted fees. Some smart people there, and a whole lot of inexperienced. Someone today is talking about an ‘appraisal typo’ to the tune of $100k dollars. Another guy is wondering how to manage his first new construction assignment for a million dollar project, apparently ‘there are no comps’. And there it is! Exactly what I was looking for and knew I’d find. The reference to the $160 1004 order appraiser. They’re all like that too, that’s how they post big numbers, riding the amc train. One only needs to read Reddit Appraisal for a few minutes to have a rather clear understanding that appraisal management companies are not selecting appraisers based on quality of service or experience factors. It’s appraisal 101 for beginners all damned day long over there with non stop references to how to game the system with outsourcing, discounting, and appraisal management companies. I took a screen shot of the first discount fee reference I found, but I’ve seen better. One can hardly even read that site for a minute without some pro amc reference. I should get on there just to troll them to death but they’ve probably got an amc friendly mod and would just end up blocking me. That’s usually what happens to truth tellers on Reddit, ban squads. Reddit is an echo chamber for the hopelessly inept.
Have questions about life? Ask POL! SWIM wonders if that’s a good idea.
https://www.reddit.com/r/appraisal/
I would say several things about this ongoing situation:
1) Any appraiser doing a 1004 report for $310 is just digging a grave for themselves & everyone else – And unfortunately it appears the funeral arrangements are well underway – JUST SAY NO!!!
2) AMC legislation needs to be overhauled-anything that can be addressed either through Depts. of Consumer Protection or State regulations where these AMCs do business is imperative
3) Obtaining as much NON-AMC work is a sure way to help ourselves – there is SO MUCH of this work available if an appraiser is willing to do a little detective work and be a true entrepreneur – instead of having a disgruntled employee mindset where you’re just grateful for your AMC bowl of gruhl-
Now is the tine for all of us to re-invent our profession – before “THEY” do it for us
Until you find a way to fire up homeowners over this GROSS OVERCHARGE you have no chance of winning.
If I belonged to an intelligent appraisal group (The AI doesn’t qualify) I would initiate a class action lawsuit for all homeowners to join and promote it on every news service. The fact that they are intentionally misleading homeowners and forcing appraisers to stay quiet about their crime guarantees homeowners a win in the courts.
Charges: Theft By Deception (Open & shut case)
Counts: 100,000,000+
Settlement: In the billions
Bonus 1: If the homeowner (borrower) received their HUD-1 via fax or email they can also file a class action for wire fraud. Fine: Up to $250,000 / Prison Time: Up to 20 years…PER COUNT.
Bonus 2: If the homeowner (borrower) received their HUD-1 via mail they can also file a class action for mail fraud. Fine: Up to $250,000 / Prison Time: Up to 20 years…PER COUNT.
99.999% of AMCs would be bankrupt overnight.
Once they lose in the courts, those who remain in business (if any) will stop hiding their fee on the HUD-1 within the appraisal fee. This will allow appraisers to raise their actual fee to where they should have been years ago ($600+)
Do we have any gutsy appraisers out there willing to follow through with this course of action?
Definition of Theft By Deception in my state:
The base definition reads: “A person is guilty of theft by deception when the person obtains property or services of another by deception with intent to deprive the person thereof.”
It then goes on to list several different circumstances that are considered to be deceptive by the law, including:
Creating false impressions of value or intention
Withholding information that could affect judgment
Failing to correct a false impression that has been created
Issuing a check or similar payment order knowing that it will not be honored
AMCs meet the standard for 3 out of 4 of the above mentioned qualifying points.
You have your solution to the problem. Homeowners will jump on a class action with all 3 feet if they believe they can make a few bucks. Just Do It Appraisers. Just Do It.
Thanks Retired. I kept your comments in mind when I fished out those old Way Back Machine links.
Because I knew I had heard those same arguments before, years ago.
Class actions are fulfilling but I’m like wanting that enchilada smothered as well. Racketeering, collusion, restriction of trade, deceptive business practices, harm to consumers, violations of Monopoly statutes. And what you said. Two class actions, one for appraisers and one for consumers, both harmed by amc’s.
When it comes to class actions, initiation of them is not always in the consumers hands. Sell that to one of the class action networks, see if the lawyers are interested. There are networks and online posting boards where people suggest and brainstorm what could rise to the class action level. Because you’re right, if consumers can simply sign on to earn an extra dollar, they get on board. A never ending stream of late night class action legal commercials are proof positive of the concept.
This just in; Camp Lejeune bottled water now outpacing sales of Bud Light.
https://www.classaction.org/list-of-lawsuits
We don’t need a brave appraiser to initiate anything. The proof work has already been accomplished over the past decade on this Appraisers Blogs website. Just email the contact people at that website linked above and pop them in a link to this blogs page. You never know, stranger things have happened…
We are diligently gathering information to present to wise counsel.
Who’s willing to donate and take part?
Thank you Pat. Happy to see that someone is willing to step forward and do what should have been done years ago. I no longer appraise property but I am willing to assist with the effort. Truly wise counsel will quickly realize that there is so much money to be made from one or more class actions that they don’t require money upfront. How can you be reached?
pturner@peturner.com
Open to all who wish to help
I’d love to be on board in some capacity. When you have your plan together, let me know how I can get involved. Thank you for your efforts!
Jason, Email me your contact information
Pturner@peturner.com
Pat Turner
Jason (below) appears to be on board. Count me in Pat. I am hoping that you are the world renowned Pat Turner of VaCap fame.
The one and only
I don’t know about fame
But we will need Jason as well
Pat
I have one observation, not a snide remark because I am retired and grumpy. I am 74 years old and have been appraising for 32 years. I still take assignments, because I enjoy the work and the added income. “Added income” you say, what does that mean? I started taking my SS when I turned 65 because of the slow market. In truth I don’t need the appraisal income to live on, and while I don’t take any 1004 work in SE Michigan for less than my normal fee-no discounts- I can see where some appraisers take a lower fee just to stay in the game. In truth we are aging out as a profession. I think one answer would be to make the disclosure of the fee received by the appraiser to be disclosed in the report including any transmission costs, possibly as a USPAP requirement. I think this is a way to start educating the public about the fee dynamic.
My first lender appraisal was in 1985. I receive a personal check for $275 from the homeowner at the door. So, WOW, are we saying the standard residential appraisal has increased $25 in 38 years??? BTW, I terminated my lender clients some 15 years ago. It was my personal and professional emancipation. There was and still is a healthy amount of NON-lender appraisal work in the market.
We need action on the state level NOW
Please send me a copy
Pat, you don’t need a copy, because all you need is to sign up with a few dozen amc’s yourself. Document and save the bid requests, track back the lender and realty agents, communicate about the fees. You’ll have more ‘evidence’ than you know what to do with after only a few weeks. The one question the amc will refuse to answer is; What was the consumer charged. The appraiser can still find that out though and if you miss the bid, there is no engagement, you don’t have to worry about client confidentiality. The amc’s have played it fast and loose, presuming appraisers would opt out rather than pushing back. Nobody will care, the scope of the issue is incredible. Amc’s handle 80% of all mortgage lending work in this country. Unearned fee raking by amc’s is an open secret that everyone already knows about. Separate billing for separate services. Click the photo of text I just posted a minute ago, a good summary of the language involved with these clever work arounds.
Want real solutions? Argue for force separated billing and demand an audit of amc’s total billable amounts, compared to consumer charges. The comparative ratio will be incredible. The amc’s have been fee raking beyond appraisal services too. Many of them fee rake on the waiver side, as they work with third party photo takers and realty agents for simple PIR level basic no value inspection services. Amc will pay a realty agent $50 bucks and charge the consumer $250+ for PIR equivalents. That’s what I learned last time I refinanced. Skating by on the waiver did not save me very much money. Yet the amc’s split ratio was likely twice as high as if an appraisal was ordered. This is the sort of motivation which drives the continued advocacy against sound in person human appraiser full service appraisal ordering.
Amc’s, ‘managing’ appraisers right out of the picture since 2006.
This is about knowing what you are worth. If you know what you are worth, then go and get it. Don’t be that appraiser that want’s to make-up the difference in the lower fee by completing more work. This is stupid and destructive to your self worth and the industry as a whole. How do I raise my fee? 1. Just do it, just like a ripping off a band-aid. Just do it. 2. Take tons of classes and become better, become more knowledgeable about what you are doing and why. I have been able to keep my fee high throughout this time period. Yes I have significantly less work, but I’m still getting paid more than the average appraiser looking to take anything at any fee.
Hell yeah Spencer. I was reviewing years past work files, just comparing volume. I was capturing more income with literally half the working effort or less, simply from moving away from amc’s. A few years back a major lender was paying me $750 base per 1004 & +$200 for just a rental form tag on. What a shame about that company, they’re still technically in business, good luck reaching anyone. My contact there was like the entire appraisal department is gone, and she was just waiting for her layoff notice. That’s when I was like, well, I’ve always wanted to get into lawn mowing. Somehow I keep picking up a single now and then, just enough to keep moving. What I’m not going to do is bail on mortgage lending and field services, that’s what I like the most. And that’s where consumers need the protection of the valuation industry. Any line defined beyond the point of GSE service is just losing ground, eventual total defeat.
There would be plenty of work to sustain the meager volume of appraisers left today if not for the waiver programs. FHFA; actively working against sole proprietor small businesses, purposefully colluding with corrupt organizations like REVAA to have fewer appraisers and more corporate influence. Mortgage backed securities ain’t what they used to be. The grand automation experiments will fail, however much time will pass before the bureaucrats allow facts to interfere with their bloated egos and under the table pay outs. Amc industry gross misrepresentation of what is best for American consumers will eventually have to be acknowledged and reconsidered.
The amc’s had a easy ride, more than a decade on the upswing. Arguments defending waivers, automation, avm substitutions, and parea, are going to be stretched pretty thin one of these days, they already have had to fall back on fictitious slander just to finally crack the lid on these special interest give away reformation programs. They’re going to reconsider one day when shtf and there is nobody left to redirect the accountability. Because the truth is they’re all backed into a corner with their lies that everything is the appraiser fault, and they all know that’s simply not true.
What happened to the 2019 Appraisal Fee Transparency Act? This would have helped to be able to list on the appraisal what we were actually being paid and how much the AMC’s are skimming off the appraiser.
https://www.congress.gov/bill/116th-congress/house-bill/3619
it died in committee in the Senate after passing the House
That’s too bad. Any reference for why the senate voted against fee transparency? They should have just limited the bill to that one single issue and not tried to tag on the other items.
no idea – that’s where good bills go to die – in committee. especially in the Senate. it was super clean coming out of the House too.
Thank you James. I’ll take a quick look, that’s easy enough.
https://www.billtrack50.com/BillDetail/1135477
https://www.congress.gov/bill/116th-congress/house-bill/3619/all-info
Second link, right side of page, more on this bill two links.
[Congressional Record Volume 165, Number 112 (Friday, July 5, 2019)]
[House] / From the Congressional Record Online through the Government Publishing Office [www.gpo.gov] / By Mr. CLAY: / H.R. 3619. / Congress has the power to enact this legislation pursuant to the following: / Article I, Section 8, Clause 1 of the United States Constitution
It passed constitutional muster.
https://www.cbo.gov/publication/55797
Congressional budget office report.
H.R. 3619 also would require appraisal management companies to itemize appraisal fees in mortgage loan documents. CBO estimates that the cost of the mandate (primarily for administrative activities), would be small because those companies already collect the fee information to be disclosed, and because a number of states already require such itemization.
They sort of did not understand the importance of the issue. Reads like a punt back to the individual states. I looked for minutes but am not sure how to find committee minutes. That had bi partisan support and they spent forty something minutes on floor debate, then shelved it. One could get in touch with sponsors and co sponsors requesting a revival and second round try. That’s how the lobbyists and trade groups get these things through, phone calls to committee members, sponsors, and co sponsors. It was debated by the ‘Committee on Banking, Housing, and Urban Affairs.’ This is what people often don’t understand about the mechanisms of government, one does not need a lobbyist to make those kinds of requests. Anyone with enough time and energy to do the above research, and actually write letters to request trying to push this through again could accomplish the goal. One could submit the above to their local state agencies and state reps to ask for a state based legislative introduction. Which would be actually more simple, as the bill did pass constitutional analysis muster.
That’s how these things shake out, the bureaucrats shuffle the bills back and forth, bury them deep in peat moss, dig them up later for additional review, bury them again, and if the paper survives, one day on repeat rounds may pass. My money is on a REVAA lobbyist making a counter phone call which resulted in the shelving of the proposal. The amc industries entire multi billion dollar business model is structured around service fees not being transparent or clearly separated.
This is an illustration of how TAF leadership continues to fail the appraisers this group is supposed to serve. Why didn’t they push and lobby for this? One presumes TAF has enough clout to get something as simple as this bill passed, if they chose to do so. We move for a vote of no confidence in chancellor Bunton’s leadership. With friends like this, who needs enemies?
10+- years ago I was invited by Solidifi to attend a meet and greet happy hour in downtown Phoenix.
The alcohol was flowing freely, which led Solidifi Staff to brag about their margins, Top 15 Lender Client List and quarterly bonuses.
I don’t know why I was invited as I don’t think I had completed more than 10 orders for them. I discontinued my relationship with them immediately thereafter.
Oh Dave H, you simply did not understand where you were at, and whom you were speaking with. It’s like if you want to be in with the drug dealers, one is expected to partake in a puff, to prove you’re not a snitch. Same sort of situation with the amc companies. Initially they had to sift out the unethical appraisers from the ethical ones, in a climate where ethical appraisers dominated the field. The amc companies utilized disincentive practices and incentive practices. Appraisers whom were identified as not being pliable were hassled out with insane volumes of stipulations, revision requests, fee and turn time inquiries, to the point engagement was untenable. Ethical appraisers voluntarily left. By design this allowed for more simplified straight forward enticement without as much exposure regarding corrupt trade practices. At the time regulators were still considering if the amc companies needed to be better regulated, or if the already erroneous excess regulation imposed on appraisers would be sufficient.
So these companies engaged with all manner of enticement, and continue to this day with sponsoring of live meet and greet industry events. All you had to do was take a drink bro, you could have been on the inside track for the amc company to literally funnel the entire workflow in your covered area to your company alone. This is how appraisers whom work with amc’s capture the lions share of orders ahead of other appraisers. Violations of federal registry guidance on appraiser selection but who has time to read that. This is where the amc industries support of fourth party typing services, runners, third party inspectors, and coordination with tech companies like Alamode to offer automation and comps sharing services comes in. Amc’s have maintained a very well oiled racket.
Amc’s stayed under the radar for quite some time before they were able to co opt the appraisal industries leadership, drive away the deplorable appraisers whom still believed in ethics and fair dealings. That’s when the gloves came off. The amc industry systematically decried lack of servicing by appraisers while simultaneously utilizing the leverage of all the pilfered fee raking to develop the automated systems we are observing rolling out today.
These companies played the long game and despite some of our best efforts as industry watch dogs, very few actually paid attention or comprehended the gravity of the destructive force the amc trade groups goals of complete lending industry reformation would have. My laymens statement on the matter was; Amc’s don’t just want a piece of the pie, they want it all, to completely dominate the entire valuation services industry. For those appraisers talking about ‘just get away from mortgage lending’, well, where do you think this is headed next? These companies are not going to stop with mortgage lending. Your precious VA, federal contract systems, legal, probate, divorce, bail bond, and other non lender work will eventually be captured by the amc market. That’s where PAREA comes in. Do you guys honestly believe amc’s will contract and wait for the lending market to turn, and not continue on with business expansion efforts? They said the amc’s could never get this far, yet here we are. We continue to warn people that entire industry capture is a very real and pending possibility. The amc industry has now partnered with a wide variety of tech industry startups to speed things along. Enter the new forms, TAF’s avm accreditation program, integration of amc interests as regulatory advisors, discrediting of the existing appraiser model, PAREA, etc, etc. The amc’s industry capture is accelerating at a breath taking pace. Chaos by design. Amc’s will capture your complete work flow upstream of you, and every single amc employee will be a PAREA graduate appraiser. The amc industry is right now preparing to shift from a management model, to a fulfillment model.
Hey retired appraiser. If you’re running for Office, you’ve got my vote!
Circa 2010. ‘Solidify is a full fee model with…’ (attached)
They would brag about how the Canadian owner dude wrote out his original amc business plan on a restaurant napkin. As inspiring as a ham sandwich.
All the amc’s shifted their billing models and engagement models over time. There are none left whom adhere to ethical principals, the allure of legal junk fee billing was too tempting. Over a decade later there never was meaningful oversight applied to these unnecessary junk fee raking middle man companies. If any other company engaged in such deceptive billing practices this would be illegal, but for amc’s, free regulatory pass. Rather, the amc’s bragged about record setting business growth to the same industry which was pilfered, proclaiming themselves partners to the appraiser as a convenient cover to deceive those whom may inquire what’s going wrong within the appraisal industry. The appraisal industry did get raises, it’s just all the money went to the amc’s, appraisers often received less than before. Appraisers whom did not play ball with amc’s predatory assignment practices and fee pilfering methods were subjected to restraint of trade practices and effectively prohibited from participation in their own industry sector, which was providing appraisals for mortgage lending services. At the time pre amc domination, roughly four our of five licensed appraisers participated with mortgage lending. Our ranks increased, there was opportunity for more diverse hires, being an appraiser was something anyone could achieve with dedication ethic and effort. Consumers enjoyed reasonable value protections in relation to their lending interests. The amc companies took the opportunity and protection away, the appraisal industry has contracted ever since.
Dodd Frank Reg Z on Appraiser Independence and C&R (Customary AND Reasonable) billing was enacted into law. Before this had time to take effect, lenders and big box amc companies like Rels and others, immediately lobbied the CFPB to install the ‘safe harbor rule’ for C&R billing. Shifting the customary AND reasonable billing requirement to customary OR reasonable, thereby eliminating the $10,000 dollar PER INSTANCE DAILY RECURRING FINE, for amc companies engaging in such predatory billing manners, which was the original spirit of the law. Basically C&R was to force the amc to bill separately for it’s distinctly different service, as their destructive effects in only a years time of HVCC regulations (which were sunsetted/ substituted at the time with Reg Z implementation), the amc industry had already drove literally a hundred thousand appraisers away from mortgage lending, and many other tens of thousands of appraiser licensees simply quit. There was a Federal Reserve comments board on the matter, which contained thousands upon thousands of upset and heartfelt appeals to not let these predatory unnecessary amc middle management companies retain this quasi legal loophole to exploit consumers and appraisers alike.
Flash forward today; The appraisal management companies (amc’s) successfully raked billions of dollars, grew at a record pace for well over a decade, and drove approximately 150,000 appraisers out of business. For the 80,000 appraisers left, roughly only 20,000 are even willing to work with amc companies. That number is relative, as operating under the amc model, one in five or less appraisers actually can acquire stable work volume. Amc’s basically tap into a fifth of a fifth of the remaining appraiser market, having estranged a few hundred thousand appraisers whom actually adhere to ethical principals along the way.
Appraisers whom work with amc’s get a free leg up on competition, they are enticed to violate appraisers own ethic rules on ‘not providing a thing of value to be the preferred appraiser’, by discounting the appraisal fee, colluding with the amc to keep their billable amount a secret from mortgage borrowers and the mortgage lenders, and are therefore rewarded with an excess of order requests. Preferred amc appraisers whom discount in such a manner are known to receive 100x, and often far more to the 200x or 300x volume of appraisal assignment requests, compared to appraisers whom maintain ethical compliance with the thing of value rule and also still bill C&R ‘as if no amc company was involved’. It is supposed to be unethical for the appraiser to bill in an opportunistic fashion, charging more here but less there, for the exact same service. The amc companies will occasionally and reluctantly pay a C&R fee to appraiser scabs whom cross the long standing industry picket line. They will turn to companies like ‘Appraisal Scope’ and ‘Regorra’, to source appraisers whom are willing to ignore ethical principals, as those distribution companies absolutely refuse to provide appraisers tools to protect ourselves from the predatory appraisal management industry. If an appraiser signs up on those sites, it is impossible to avoid a relentless stream of appraisal management company solicitations. Many amc’s send out a hundred fee and turn time request emails for every single individual order to be placed, also refusing to abide the FCC CAN SPAM ACT regulations on offering unsubscribe options for commercially orientated solicitation emails. Over three in four appraisers now refuse to even sign up for those sites due to the distribution platform companies advocacy for the continuation of predatory amc industry practices.
Amc’s, managing appraisers right out of the picture with predatory unethical practices since 2006. FNMA approves, that organization has rewarded the predatory nature of the amc companies with special favors and elevated work distribution status for their new appraisal modernization programs and the property data collector approach. Which of course will be fourth and fifth party outsourcing managed by the third party, meant to eliminate even more licensed appraisers. This will destroy what little incentive there is left for independent licensed appraisers to provide a necessary check to balance, standing in between an increasingly predatory realty and lending community and the entire body of American citizens whom would use GSE lending services to acquire a mortgage for a real property loan. It is shameful for the regulators and GSE managers to have allowed this amc farce to continue this long.
https://ncua.gov/regulation-supervision/manuals-guides/federal-consumer-financial-protection-guide/compliance-management/lending-regulations/truth-lending-act-regulation-z
The amc’s quasi work around was made possible because all the regulation was structured around the backbone of the C&R rule, which basically was meant to eliminate the amc industry from ever taking a strong hold. Therefore the amc industry was never specifically regulated. And that’s how they get away with deceptive practices which are prohibited with literally every other sector of lending. The bozos at the white house invited the amc industry to represent the entire appraisal community at the PAVE task force. Our TAF leadership group is not even ran by a licensed appraiser. TAF has turned into an extension of the amc industry, that group is richly compensated.
Many appraisers whom take advantage of the lions share system are AI members, so they have a negative incentive to call for reform of these grossly incompetent regulatory oversights. Rather than the amc industry being fined billions of dollars to reign in better consumer protection standards, they were allowed to excise billions of dollars in junk fee billing instead, decimating the entire appraisal industry over nearly two decades time. Now appraisers are also slandered as a bunch of racists for daring to stand up for consumer protection and being unable to hire anyone outside of our immediate family. The TAF sanctioned Brookings Institute slander allows additional groups to tap into some of the amc’s pay to play system. TAF specifically implemented a PAREA program to assure the amc industry has fresh blood and a new source of licensed appraisers whom would be more pliable and less informed, in order to continue to wholesale pilfering of the American consumer and appraisal industry. Most PAREA graduates will likely be sourced as employees of appraisal management companies. Equity!
This is also why I will never be an AI member. They have bowed and kissed the ring of all AMC’s. They are not there for our interest, rather the interest of their pockets from the scraps the AMC’s earn to buy AI off. Their reluctant responses towards AMC’s and present finger pointing toward appraisal bias add to the point.
S.P, its easy to criticize A.I, as they certainly have been part of the problem. The bigger and biggest issue has been that the appraisal profession is very splinter group of professionals(?) that have NEVER been united behind a cause and/or issue. The lender and lender interest groups have ALWAYS known this fact. Thus, they have been able to totally control the appraisal process(fees, TT, report requirements etc, etc) for lending purposes. So appraisers, with few exceptions, working for lenders/AMC must comply or get our to town.
Never? Something about Dave Biggers…
https://web.archive.org/web/20100501175340/http://www.appraisalpress.com/news/articles/fees_new_rules_new_data/
Appraisal fee reference introductory article from Dave Biggers, pre Corelogic buy out of Mercury network systems. The ‘Appraisal Press’. An important primer describing how updated regulatory efforts were supposed to help appraisers, not harm appraisers. Thank you to the appraisal management industry for ruining what used to be a great thing.
https://web.archive.org/web/20100418143229/http://www.appraisalpress.com/
Appraisal Press sampling, front page.
https://web.archive.org/web/20100424195343/http://www.mercuryvmp.com/analytics/
The ‘Appraisal Fee Reference Guide’ introductory landing page.
https://web.archive.org/web/20130327210547/http://www.mercuryvmp.com/documents/Free_AFR_February_2010.pdf?ClickID=AFRDOWNLOAD&ClickThruEmail=&ClickThruCustomerNumber=0
Redirect page which seeks to call on an old link for an old doc, from the actual web host. The actual document scrubbed from the Mercury, which of course was part of the Corelogic efforts to wipe away the history of the Mercury network and reform that platform to be pro amc orientated, rather than anti amc orientated as it was originally designed. Can’t have the dwindling body of ethical appraisers whom remain, annoying everyone with legitimate market data on fair fees to charge for appraisal services.
https://appraisersforum.com/forums/threads/customary-and-reasonable-fees-90-days.170927/page-6
When the document dropped, the Appraisers Forum thread on the matter ran nearly fifty pages. In retrospect… Most of those appraisers had no frigging idea what was about to hit them, and how short sighted they were for arguing against the fee raking restraints of amc’s. The amc’s churned through most of them, some made it, most bailed entirely on mortgage lending. I was on the forum way back then, trying to warn people about amc’s, nobody listened, they were too busy with a never ending flow of easy work assignments. I kept going through amc’s trying to find an ethical company to work with. After about I think 4-6 years I just gave up, there is no such thing as an ethical and reliable appraisal management company. They all fee rake. They all use deceptive practices. They all run bait and switch programs. They all have high employee turnover and inadequate training. The amc industry is irredeemably corrupt and I have a client folder for nearly every single one of the entire TAVMA member list to prove it.
However, a little progress, actual document tile was discovered for the Mercury fee reference publication. If anyone has this document, I think it would make a really interesting article to re publish it on this site all these years later, give people some better perspective on ‘fair fees’. Someone must have saved this in a digital folder somewhere.
; “Free_AFR_February_2010.pdf”
SOB! I found that damned Mercury published fee reference document wayback link, I have been looking for this one off and on for the past ten years. Sadly, was not able to pick the actual document. They only published this one single time before the heavy hitters phoned upstairs to the CFPB to carve out their customary OR reasonable work around, thereby nullifying the need for valid consumer fee surveys which amc’s would have to abide or suffer the $10,000/$20,000 daily recurring fines.
But take the time to read and pdf print the other links. Especially for people whom entered this industry after 2010, you have no idea how devious these companies are, how damaging their effects have been, how extremely aggressive they have behaved. We used to have a different tone and real leadership, people in the valuation industry actually did care about ethics, fair dealings, accountability, defending the sole proprietor model, real support networks for small business owners. Appraisers were not just a bunch of spineless amc sell outs or arguing to just abandon citizens to predatory lending models and middle management pilfering like we observe today. There was no ‘appraisal coach’, because there was no need to sell out your fellow appraiser to get ahead, we all pushed through together and there was comradery and respect for each other. We left no ethical appraiser behind and took care of each other, totally opposite of how the amc industry has reformed the valuation service industry into a predatory dog eat dog model.
Which is why that articles like the one we’re all commenting about on the blogs here, although seemingly simple, are so important. There is bonafide proof of criminal activity, legitimate evidence, just sitting on an open web page, shared freely, as the criminal amc industry walks scott free. They do that every day of the week and should have been liable for immediate fines which would have put the amc’s out of business or forced them to bill separately for their distinctly different service. Imagine the 200,000 appraisers whom could have been sitting next to you today. Imagine not struggling for work. Imagine never having to discount for volume. Imagine a TAF no co opted and beyond corrupt. Imagine respect instead of slander. These are the fruits of the amc industry, TAVMA and REVAA they certainly did ‘manage’ their way to the top, at everyone elses expense.
Hey Baggie, can you shorten your comments. I’m retire with other interests…..LOL……..
Respectfully, No. I’m not retired and everything is on the line. We’re hoping legal professionals, state agencies, regulatory persons, and lenders whom would resist these new models will read these threads. Be present or be retired, that’s your choice. I’m 100% all in all the time. Don’t make me text this in while lawn mowing out back, swear to god I will.
Mowing lawns….now that a option. lol
Listen, I know my posts are long and annoying, time consuming to read through with all the links and rich informational sources. I continue to believe that if more people were better educated on this industries history and trajectory, positive change can happen. I don’t care if it’s a one liner or a dissertation, every appraiser whom chooses to participate is much appreciated.
One day I will leave the boards. Y’all will miss me when I’m gone.
I just hope to live long enough to finish reading one of your posts..;)
Selling guides are several thousand pages each, often so are regulatory documents. All one needs to do in order to be a well versed appraiser is comprehend approximately 10,000 to 20,000 pages of government and state regulation, and be able to speed read and speed type. These days to also include competent internet research.
Appraisers really are aging out if we’re now talking about can’t get through a page of detailed blog posts. Have you tried something like bifocal assist or actually getting out of bed to read these pages? Step back from the instant coffee and try something with real caffeine.
The push for modernization, per governmental/FNMA reasoning is excessive fees, the slow appraisal process and biased appraising. AMC’s have huge part 2 of the 3 problems causing the push for modernization… In addition to the exorbitant add on fees, AMC’s will shop around for sometimes a week for the lowest bid in order to maximize their cut. This makes the appraisal process appear “slow”. Every time I picture the owner of AMC in my mind, oddly Martin Shkreli’s (Pharm Bro) face pops up.
AMCs have been ripping off appraisers since day 1.
Time to wake up & stop taking miserably low fees.
It is the bottom scrappers/boiler room type appraiser who is keeping & supporting this low fee nonsense from the AMCs.
I have one word for Baggins – obfuscate – look it up! A man’s knowledge is NOT measured by the number of words, but by a clear focus of where to start thinking.
https://www.merriam-webster.com/dictionary/obfuscate
‘Try to Understand the Roots of Obfuscate / Obfuscate comes from the Latin prefix ob- (meaning “over” or “completely”) and fuscus (“dark-colored”). That fact gives an idea as to how the word can refer to making something difficult to see or understand—much like how dark, dirty water makes it hard to see the bottom.’
More like you just described the appraisal industry after appraisal management companies became involved, straight lied through their teeth about every last little detail, and most appraisers walked away.
Over a hundred and fifty thousand lost appraiser careers, double that for opportunities never realized, appraisers that never came to be, their opportunity pilfered by the amc’s as well. Let me ask you when would be your measure of an appropriate time to really dive into the issues, become well versed, and care? Think of the gravity of an entire industry forming around what would otherwise be commonly understood as illegal behavior, and was for a brief period, clearly defined as illegal behavior in codified law. That is what this article is all about, the illegality and offensive nature of amc junk fee raking.
Agreed that word count is largely irrelevant for literate people. Again, you’ll miss me when I’m gone. I’m like this websites own free service labor, I research anything requested, on demand, thoroughly at that. My primary motivation is to counter the never ending lies and false claims of the appraisal management industry. In this installment we provided meaningful perspective with real world historical references on the appraisal industry tone and activities then vs now.
The word you were actually looking for is elucidate.
Physics had Einstein, Cheers had Cliffy Clavin, politics has Donald Trump, and Appraisers Blogs has Baggins. Careful what you wish for…life online would be boring without The Bag Man. I may not always agree with him but you have to respect a guy that can write in his sleep.
When I retire from appraising, I’m not going to post on appraiser blogs for 15 years like retired appraiser! Jeez man take up stamp collecting in your senile years!
You can still learn something from the past appraisers. Never be to good for anyone.
Ralphy is busy making $300 per appraisal and thinks he’s getting rich. He should be earning $700 to $1,200 per appraisal. I wouldn’t take comp photos and make a trip to the county records office for $300.
Then call me “Disgusted Appraiser”. I quit half way through what should have been a 40 year career. Why? Because I refused to be strapped by a barrel by AMCs and raped daily. I also refused to do work for attorneys to survive. I refused to teach appraisal courses like many of my peers did to survive and I refused to live off of commercial work that did not appeal to me. I easily lost 150+ clients nationwide when HVCC kicked in and was forced to fire people that I had spent years training. If it makes you feel better I am far from retired; I simply moved to another field that pays ten times more than the new and improved appraisal profession. Hint: Just because you retire (QUIT) appraising doesn’t mean you can’t still be angry as L at AMCs over the hijacking of a profession that you once loved. If I have the energy, I will be fighting those sunny beaches (AMCs) thirty years from now.
Don’t see how disclosing the appraisal fee on the completed appraisal report will solve the injustice being put on appraisers by AMCs. AMCs and lenders have all the cards to control appraisers.
It certainly won’t fix the AMC nightmare. I have been disclosing my fee on the report for many years. I believe some states are required to disclose the AMC fee as well. I believe having to disclose disclose the AMC’s fee might raise some eyebrows for the folks paying for the appraisals if they actually read the report. The real issue is the AMC’s burying their fees in closing statements by calling them part of the appraisal fees, which we all know is BS. These actions should be criminal if not already.
Their actions are indeed criminal (theft by deception on the largest scale in U.S. history). They are lying to the homeowner and the IRS by hiding their bloated charge under the disguise (hence the word deception) of the appraisal fee. If the HUD-1 disclosed the true appraisal fee appraisers would be able to charge far more for an appraisal. A class action lawsuit by homeowners is the only way to put an end to this crime and free appraisers from what I refer to as “voluntary servitude”. Thankfully, I didn’t volunteer to board the ship before it sailed.
RA, you seem very knowledgeable in these areas. I would love to get on board with a group of individuals really motivated to take serious action in order to salvage the appraisal profession. I have some extra time these days, but certainly not enough time to take on organizing a class action(s) alone. If you have any leads in this regard, let me know please. #HadEnough
Pat Turner, you, and I appear to be on a similar page Jason. The toughest part is having a plan, and we have a rough draft in hand. I have had 14 years to dwell on this topic, as well as a few failed attempts to terminate AMCs. This plan stems from something I attempted years ago (exposing their crimes through the media). Although I convinced Ken Harney of the Washington Post to write about it regularly, it never gained traction. This plan has massive legal teeth if wire and mail fraud are introduced as part of the suit. It also has the ability to go viral both because of the number of homeowner affected, and the amount of money involved. It would not surprise me to see it dwarf the Fox News settlement. Getting homeowners to sign on will be a breeze with the proper online platform. As Baggins noted, finding a law firm that is not afraid of taking on the banking lobby (AMCs) is the key. We must convince a firm that appraisers are willing to go out and sign up homeowners for the class action in order to be taken seriously. I firmly believe that 1,000,000+ angry homeowners signatures can beat the banking lobby in court any day of the week. We lay the foundation of sign ups via word of mouth, Facebook, YouTube, and something similar to Change.org. 4.6 million people signed a petition to have Amber Heard removed from the Aquaman II film. How many homeowners would you guess would sign a petition if they learned that they were being robbed by AMCs who have been engaging in theft by deception for 14 years? If it gathers enough steam it will go viral; if that happens you can nearly always capture the attention of the national media and double if not quadruple your numbers. I’ve seen it happen time and again. The question is: If appraisers will not boycott, donate, or write letters; would they go to the effort to sign up those first few thousand homeowners? Appraisers are the only wild card in this gamble. On the flip side, if you have a worthy injustice, once you get past the first few thousand signatures, social media, online petitions, and the media will typically take over the heavy lifting.
Jason,
I spoke with Pat Turner last week to discuss options. I am awaiting word from him on how a recent meeting went before moving forward. I have nothing to lose by taking another stab at taking down AMCs via legal means. I have no desire to return to the business and I could truly rest in peace at the end of my life knowing that AMCs were wiped off the face of our planet.
RA, there is a little chatter on appraisersforum.com but no real details. Google “ARCC appraiser”. Based on the limited info I have, from a couple of brief emails, things went very well. I spoke with Pat just prior to the “meeting” but have not spoken via phone with him since. I actually just sent him an email today and I am awaiting a response.
Call me tomorrow please
I understand your explanation, but many borrowers don’t read the report in much detail and the $700 +/- paid can always be justified by the AMC as just a appraisal processing fee. I gave up doing AMC work 20 years ago, when it became very apparent that lenders and lender interest groups were moving toward controlling the entire appraisal process for mortgage lending. They control the fees, turn times, bidding process, comp selection, adjustments, scope and most other appraisal methods. Appraisers can comply or get no or minimal work OR leave. I chose to leave for other appraisal clients. There is certainly appraisal life, after working for lenders for 20 years.
‘Physics had Einstein, Cheers had Cliffy Clavin, politics has Donald Trump, and Appraisers Blogs has Baggins. Careful what you wish for…life online would be boring without The Bag Man. I may not always agree with him but you have to respect a guy that can write in his sleep.’
Just getting back to look at a few semi recent threads. I had an email melt down and unsubscribed from everything, lol. Thanks for the kind words though. I don’t know exactly how or why, but somewhere along the way I became good at forming intellectual arguments in writing, speed typing, speed reading, and acquiring whatever I needed online however obscure, with comprehensive online researching skills.
I’m just going to give up, I don’t know what to do. Marketing for all year long, not a single new pick up. I’m confined to the realm of mortgage lending and default management, as that is all I know and all I want to do. Disappointing to see a decade later how many default managers fell to the hybrid approach or the amc model, often both. I’m looking around at some other distribution platforms whom poached various direct assignment clients away from Mercury and Scope, these sites are so poorly developed and managed. Regorra, Value Link Connect systems, one other I forget. They absolutely refuse to acknowledge a broad spectrum of verifiable shortcomings with their systems. The appraisal request distribution platforms are clearly advocates for the amc industry at this point regardless if they provide any safeguards for appraisers or not. However, I’ll run a last few marketing blitz campaigns first like the old days; ‘Keep my information though, because I’ll be available if you can assign orders directly and not force me to work with amc companies, which myself and three out of four other appraisers nationwide also refuse to work with amc’s.’ Despite the Corelogic tie in, I’ll continue to recommend Mercury systems or ValueTrac systems as those are the only ones which provide comprehensive safe guards against amc bidding shopping spam. The cumulative time drain of the companies allowing a hundred shopping emails for each individual amc order placed. Name one other industry where a customer is already in place, billing already secured, and a third party company solicits a hundred different licensed contractors for each individual singular order placed.
Hulk for president 2024. I’ll be happy to sign on to anything anti amc or class action related. I still need to write the important letters regarding the hopeful regulation of the avm industry. Just last week I identified a builder mls entry which was $80k higher than county records indicate. Yet another instance of clever agents manipulating avm results to create illusionary price anticipation, to keep their base price rising schemes going. For those reading this thread, please try to write a letter, then distribute that same letter through these FOUR different regulatory groups whom may review. (second link comment brings up three different selections.)
Repeat post; Letter writing request regarding AVM regulation formation.
https://www.fhfa.gov/SupervisionRegulation/Rules/Pages/Quality-Control-Standards-for-Automated-Valuation-Models.aspx
https://www.federalregister.gov/documents/2023/06/21/2023-12187/quality-control-standards-for-automated-valuation-models
Baggins,
Sadly, my Colorado brother, things have taken that turn. I’m with you, I don’t know how much longer I’ll hold out.
I’ve shifted a great deal of my work to estate and private homeowner/pre-listing work. The very few AMC’s I work for seem to be barely holding on as well. The VA work has slowed to a trickle, but that is mostly of Denver RLC fault assigning work to out of area roster appraisers, which has led to basically scraps for local appraisers. I’m busier than most guys in my area, and I know a few people with their hands on the eject handle too.
I still get the occasional random shot-gunned appraisal broadcast from some rando AMC for $400 and just laugh. I will continue appraising to some degree, most likely until the new 1004 comes out. But I don’t want to be where I’m not wanted, and the GSE’s, SIG’s, and TAF have made that clear.
Keep swinging though, you’re much too valuable to us and the industry. I’ll be writing those letters soon.
Cheers, and Hulk Kennedy for prez.
Thanks, much appreciated. My appraiser pal in Aurora hired an inspection assistant whom is an appraiser, and is getting good traction after several years of attorney marketing. If you’re willing to dress in a suit and tie, go to court rooms, be an expert witness, the right strategy can work. He’s getting $800+ per, plus various expenses and follow up. Thinking of something in insurance though, just not sure yet.
We ran up to somewhere west of Loveland a few times last week, caught a fish, took in fresh air, that was nice. Reminds me what it was like pre amc days. When I initially started I’d purposefully market to mountain area lenders, as I started in mountain, had the skills, and loved to fit in fishing trips on long drives to the rural areas.
The business model of an amc is predicated upon taking advantage of appraisers, eliminating the appraiser, and replacing the appraiser with lower priced outsourced services. The amc industry does not attract honest people and that is a bonafide fact. The appropriate flag for the amc industry is the pirate flag, all they do is abscond with other peoples stolen money, then brag about record setting business growth.
I like your home owner and pre listing strategies, I used to do some of that. Got tired of always explaining the details of engagement and client relationships to people whom just turn around and try to boss me around though.
If the amc industry was not present, there would still be adequate lending work for every appraiser in this country, we could all return to mortgage lending and create many new skilled licensed positions. Instead, we get felony property data collectors, institutionalized junk fee billing schemes, and amc criminal managers hacking appraisers email accounts on a routine basis. Equity!