quote: Our legal department has reviewed the recent bill, in depth. See bill attached, page 8- line 29 discusses the fee disclosure requirements:

It shall be unlawful for an appraisal management company to:

(c) Knowingly fail to separate any and all fees charged to a client by the appraisal management company for the actual completion of an appraisal by an appraiser from the fees charged to a lender, client, or any other person by an appraisal management company for appraisal management services;
(d) Knowingly prohibit an appraiser from recording the fee that such appraiser was paid by the appraisal management company for the performance of the appraisal within the appraisal report that is submitted by such appraiser to the appraisal management company;
(e) Knowingly fail to separately state the fees paid to an appraiser for appraisal services and the fees charged by the appraisal management company for services associated with the management of the appraisal process to the client, borrower and any other payer.
Appraisal management companies shall provide a copy of the appraiser’s invoice with a copy of any appraisal report submitted to a client or a client’s representative;

Based on the above, the AMC – not the appraiser, is required to separate the appraisers fees. The only requirement for the appraiser, is to attach the invoice to the body of the report. The AMC must then break down the fee for the client.

Regards,

Operations Manager
Nadlan Valuation Inc.\

does this stand correct? no other amc is doing this

Randa, some of us still believe they are one and the same thing. Property condition analysis is an opinion…contrary to sophist bleats by bifurcated appraisal hucksters (including FNMA). It is not a ‘fact to be found’. Market bounds are opinion as well. Also not indisputable facts to be found. Property appeal and apparent marketability are opinions.

Deciding whether a grey area property is legal; legal non conforming or illegal is also the result of numerous opinions developed in the field at the inspection.

I think I get (& concur) with the point that they may still have wiggle room. Then again it may not.

Shut down BREA and start over.

Seriously, we COULD draft sensible across the board state legislation that our legislature has proven they will act upon if only appraisers could unite behind a common goal. In California, AI sought and successfully obtained single sponsors to introduce their bills. The reason that they succeeded, is that they made the effort.

The opposition would have to have a specific alternative plan and have sufficient numbers of appraisers in support of it. California has two state coalitions. I am a member of both. Neither has proposed specific legislation to favor appraisers issues.

Agreed !!!

Because amc regulation was so wildly successful at protecting us from these companies last time around…

It’s up to us individually. Go with it or market yourself and your favorite lenders away from middle management.

If appraisers can’t beat the middle management sales people, whom are not licensed, do not have industry experience, and advocate against our causes. Well, perhaps it’s time for those appraisers to reconsider if they’re adequately equipped to be the key sales analyst for real property deals in the first place. With salesman, it takes one to know one. Middle managers will just find another way, nothing will really change.

merv not sure what you are trying to say?

“Work smarter, not harder.”

Good one Mr Skapinetz. We can thank the rels lobbyists for lobbying away a previously proposed hud1 disclosure form which clearly distinguished between appraiser services and appraisal management costs.

I’ll take your recommendation and add another to it; New FNMA forms should have entries where appraisers must list the names of all persons and companies they may have relied on for informational and development purposes, as well as documenting the distribution of the consumers total appraisal services fee.

Let’s see here, they used a report typist out of india, used a non licensed inspection runner, paid for a third party amc order management app to capture higher rates of blasted orders, paid multiple technology fees, and discounted the appraisal fee to what appears to be well under 50% of the base consumer charge. Hey, why wasn’t cost savings from reduced cost vendor services returned to the borrowing consumer? This industry relies on pressuring appraisers into the need to use ancillary services. There is a better way.

Dollar signs in their eyes, and tunnel vision as a result.

Perhaps it’s coincidental, perhaps not, but there was some rule in CO I believe that if working with an amc, we are required to state our fee in the report. We’ve had several of the major CO based lenders move away from amc’s and have been direct assigning for several years now. Some lenders will run direct in CO, even though they still use amc’s elsewhere. It does not really matter though, these requirements never stopped some of those amc’s from playing bidding games, assigning by fee, and redacting that information in the review process.

Who’s still holding their breath that anyone else will make a better advocate for their small appraisal businesses other than themselves? All it takes is one or two good direct assignment clients. It’s not rocket science.

The most profitable companies in the past several years are those whom provide nothing, shuttle everything, and have others do all the hard work. Sad but true, it’s been going around.

There is a lot to be said about traditional merits of doing the job yourself, not outsourcing duties, and maintaining a direct customer to vendor uninhibited relationship. Don’t get angry, get even. When amc’s screwed me over I simply turned around and marketed to the lenders directly. “When you’re finished using amc’s, I’ll be available for direct assignment orders.” Most lenders are unaware they’re missing out on access to roughly half of this countries available appraisers by choosing to work with amc’s.

Appraisers to this day still hope that the government will save them from their own client management decisions. If appraisers choose to work with amc’s, they should have a clear understanding by now that only 1 or 2 in 10 will be front line appraisers, and the rest will ride the bench hoping for pick me ups the discount cherry pickers did not accept. They will never win on fees, and at the first possible opportunity when demand subsides, the amc’s will be back to their normal approach of selecting by fee, bidding, and playing appraisers against each other.

Just stop accepting the orders, solicit to lenders directly, and prioritize direct assignment clients first. Word gets around quickly among mortgage lenders that the other outifits whom are not using amc’s are getting superior service, with happy appraisers. And don’t be fooled, every single lender whom also supports va lending knows all about it. On one hand while forcing appraisers through amc outsourcing, they’re also still managing direct assignment via va systems internally on the other hand. Illusions.

I informally looked at a chase appraisers report the other day. This appraiser just copied dated assessed value record figures for land, had 5 comps with adjusted value indicators 50k+ apart, left the majority of the report blank, boilerplated the rest, and some how still got some silly number like 482 or something for billing. It’s no mystery why when the buyer walked to a new lender, the new lender refused to port that appraisal over and called me in instead.

The government’s purpose is to protect liberties. The governments purpose is not to save citizens from their own poor management and financial decisions. Work with a middle man, or don’t work with a middle man. It’s a free country and a free market as long as you don’t willingly constrain yourself. I’d rather take my chances always on the edge rather than live under thumb. So far, so good.

Lori Noble that’s just totally devious and is actually deliberately misleading. I’d say “client requirement” before the information.

For all appraisers whom came in after 2008 to 2013 sort of time period, they should set aside a few weeks to read the entire appraisal scoop body of articles. This broken record keeps skipping on to the same old beat.

I’ve clearly disclosed my fee within reports and when I present to the homeowners since day 1 and never ever kept that a secret, no matter whom I was working for at the time. I will not willingly collude with a middle management company so they can rake junk fees in secret. If they were truly providing something of value, why can’t the lender pay them for that separate from the appraisers fee? Fee disclosure rules are a misnomer, it would be a violation of your first amendment right to silence a worker from being honest about what he is paid for this type of labor work. The rules to protect us from abusive corporations have been in place for hundreds of years, all people need to do is exercise them in the first place and you don’t need the government’s permission to do that.

I think I’ve said that before… They’re all the same. The thing you simply can’t get around is there is a financial incentive to drive appraisers fees down for variable opportunistic amc profit because they are not required to return cost savings to consumers. No matter how hard you try, no matter what approach you take, what counters or rebuttals you give, what you may bring to the table yourself, you’ll never get around that one point which is the quintessential driving factor for all amc’s whom do not use a cost plus billing approach. They have a financial incentive to drive your fee down and pocket the difference. They are not required to return cost savings to consumers.

It’s a money grab, like most tech gimmicks. Force a requirement, create a need for a third party tech management platform, spend a small amount setting it up, run it in an automated state after that, profit indefinitely. Technocracy is here and it’s not just a conspiracy theory. We’re being hoodwinked left and right through the entire tech spectrum. AI is not being developed, for the reasons people think it’s being developed. Most people are already so hopelessly dependent on tech, it may be too late to save them. The matrix was a documentary?

don’t thank him. He’s killing New York.