on this from 5/30/2024

press@cfpb.gov

CFPB Launches Inquiry into Junk Fees in Mortgage Closing Costs

it says they want comments – so everyone should comment – with all the hidden fees – or anything – let it all out

Maybe, probably not. The blacklists are likely reserved for deal killers, appraisers whom dare to actually be independent. Sorting out the higher fee appraisers is as easy as clicking the ready made drop down arrow; sort by fee. They can sort by any number of performance metrics, fees, turn times, rov instances, etc. There are proximity tools to limit assignment to only near to the appraiser, adjustable proximity ranges. Panels within panels, mini lists. What most likely do is just pick the appraisers off the top, which the assignment systems automatically provide preference to large appraiser firms. The amc’s whom know how to game the system will not even add appraisers on to their panels, rather will spam them off the general appraisers index instead. I can’t even tell you how unethical these companies are, except to say if the people or even the companies themselves had state licensing, I would have easily had their licenses revoked at the state level for how they’ve treated me. This is the point of middle management, third and forth party outsourcing systems; circumventing licensing accountability. ‘Appraisal modernization’.

I’m really really bored right now and would rather be working. Looks like I’ve been modernized too.

Thank you. Oh no, this can not be a full article stand alone. I buried this in the back ground on purpose. I do not break rules of access. After a decade and a half of navigating these tech systems, you learn things and stuff. Come across data accidentally from time to time, now and then a person with good working ethic is part of these systems, despite the hostile working climates. The bright side is when you call into these companies to ask questions or provide ideas how the system could be improved for the benefit of the appraiser; there is always a new person to communicate with. Just call more often, ask detailed questions about the technical processes, you may be surprised what you learn.

Most of the good faith arguments regarding the supposed benefits of automated assignment systems turned out not to be true. Prior to ‘appraisal modernization’, these systems were initially intended to be safe havens for appraisers to avoid amc’s and retain direct lender clients. The companies whom use these systems have been rotating in and out of the amc vs direct assignment circuit ever since, some have came and went multiple times. The appraisal assignments systems framework is designed to exploit appraisers. Only with reliable ethical lender side management which chooses to be fair, does the regular appraiser have a chance at fair dealings. Few and far between. “End of the line man.” To know more, simply hop on a light cycle and get in there. The internet is yours as well.

Missing the IVPI proposal yet?
https://www.workingre.com/wp-content/uploads/2013/08/IVPI-Proposalfinal.pdf
https://www.workingre.com/wp-content/uploads/2013/08/IVPI_Questions_and_Answers.pdf

That is an incredible take on the current AMC model and appraisal relationship, and should be an Appraisalblogs.com thread by itself.

Well done, brother.

“Get a Mercury MVP, Scope, Regorra, AP client appraisal request distributor access account, or one of the half dozen others, and simply look at all the appraisers fees and availability yourself. Phone a friend or just buy in, appraisers can and should be able to see the other side of these tech systems as well.” If anyone has done this, I’d like to know what my standing is on these platforms and whether or not I’m on a do-not-use list….probably very likely because I fight back when the AMC or lender is wrong in whatever assumption they’re making and I educate them. Seems like every time I educate one, that’s one less client I have. So, ANYONE DONE THIS? If so, Send me an email and let me know what you find, or give me a login to use so I can search for myself.

Or an even easier method to look at other appraisers fees; Get a Mercury MVP, Scope, Regorra, AP client appraisal request distributor access account, or one of the half dozen others, and simply look at all the appraisers fees and availability yourself. Phone a friend or just buy in, appraisers can and should be able to see the other side of these tech systems as well.

Appraisers still in the mix would certainly be surprised to learn far less than half of all currently licensed appraisers are even still a part of these tech based appraisal request distribution systems, and how wildly varied the fees are. Cumulatively there has been over 300,000 appraisers on these systems over the past two decades, tracking total licensed ASC appraisers. These days, less than a third of that number is present, which does not add up, unless one accounts for multi state licensing, which would bridge the gap from 70,000 or so remaining appraisers vs the just over 100,000 current ASC licensees these systems recognize as being active appraisers to include in the appraiser indexes. Even then, various individual clients will often only have about a tenth or less of all currently available appraisers on any given approval panel, sometimes far less than that, hundreds if not thousands more in the awaiting panel acceptance sort of section. As many as in the block or denial lists.

One of the more disheartening revelations from looking at these systems from the other side of the desk is the nature of appraiser performance rating. Because over time the appraisers performance grading ratings do not reset, and all previous clients, even if the appraiser dropped them or vice versa, the ratings applied to the appraiser from the past, are pulled forward to the future. If an appraiser received a poor star performance or similar rating fifteen years ago on these systems, that negative rating still affects you today. There is no rating for appraisers to network and coordinate which clients are better. And as clients have total control of system peramiters by which they engage appraisers, aggressive or impatient clients carry a higher probability of dragging the appraisers score down. When ever they set time acceptance to a mere two hour window, as one example. Every time the appraiser misses that, a negative grade which carries to the appraisers master profile, permanently in perpetuity and the data is never reset, an infinite shelf life of appraisers performance data.

Rendering proprietors whom for whatever reason had individual instances of negative performance grading (quite possibly due to the clients vindictive behavior or the clients own processing inadequacies having contributed to poor grading on an individual order, or something like untenable one hour to acceptance windows which the appraiser failed to respond and had lower star rating) those appraisers to this very day still have consistently lower performance grading, aka index deranking. Which the appraisers tech systems grading limits the appraisers exposure and subsequently ability to pick up new clients, as companies seeking new appraisers are shown ‘best rated’ appraisers at the top of the available appraiser index lists in the ‘build a panel’ type of interfaces. Either through general systems development incompetency, by pure accident, or possibly intelligent purposeful design, these tech systems constantly deranked sole proprietors and instead promoted appraiser firms, aka prioritizing the amc model.

Companies seeking appraisers have a myriad of options to sort the appraisers out of the data set to build their panels, most of which sorting options are tech peoples ideas of better performance, and not necessarily what matters to astute lenders or appraisers. As my appraiser pal and I were joking about this as he commented on my low appraiser rating, I had said; ‘Perhaps it’s like golf, and the lower score is better. Ha!’

These are not well developed technical systems with intelligent design, and they have failed to evolve in over a decade after their original conception. Better described as an appraisal industry version of Python or something more focused on managing large informational data bases, having various script solutions to pull and organize data in different ways as necessary. Script kiddies run the show these days. Appraisers whether they have understood this or not, as well as lenders whom bought into the illusion of the reliability or legitimacy of these systems; have had their business futures held at the mercy of tech people whom know absolutely nothing about the appraisal industry.

One somewhat unexpected revelation is how the tech companies may have shared interfaces on the assignment systems with both amc’s and lenders, and how they can readily simply click an appraiser on or off of the effective approved panels, move them into denied status category. Thousands of such instances of that as well. In retrospect we can see more clearly why one really good part of the HVCC rule set was dropped; The requirement that if an appraiser were to be removed from a lenders panel, the lender had to justify the action in writing, and inform the appraiser.

Not these days; One click and the appraiser is gone forever from that lenders panel. The appraiser is not kicked back into the pool of appraisers and simply taken off panel, possibly being able to be picked up again later. The appraiser does not know this, but the appraiser is put on what is essentially a lenders or amc’s black list. Except appraisers no longer can engage in discovery process like we used to, having found lenders blacklist and do not use appraisers lists, sharing that around, highlighting possibly unethical behavior. It’s all technical now, the appraiser is scooted into the back ground, put on the do not use list, never to be seen again. Rather than abiding rules of ethical engagements, being more transparent and prudent, they coded in do not use blacklists into the assignment systems instead. Of course they did. Why do you think amc’s bought these companies in the first place? Special pro hint; ROV’s are part of the grading sequence with some of these.

The action of forming a blacklist for appraisers whom shall not be used is actually one of a dozen core functions of the appraisal distribution technical systems. Every single company whom uses these systems has this feature availability built in. Given the lackluster management, outsourcing of scripting, general ignorance about the unethical nature of this denial of service process, likely eroding informational and systems security, it’s only a matter of time before these systems are breached. The systems probably already have been breached, but this is simply not disclosed to appraisers. As more and more of these appraisal distribution platforms come forth with their high employee turnover, it would not be surprising if one day a data breach at these companies brought that information forth for all of us to review; all the lenders and amc’s appraisers blacklists at once!

Additional insights included a mesh based cross linking network where a lender whom uses these systems often will have multiple amc’s as part of their network, or vice versa, amc’s working with multiple lenders. That is taken for granted, yet the function of the system confirms one of my long held theories of these systems; That if lenders can identify if appraisers use amc’s, those lenders will not assign to those appraisers directly, and will instead outsource to the amc. Lenders see the exact same appraisers index lists as amc’s, able to readily determine if there are available appraisers or not, despite what the amc may tell them, and the fees, if only they take the time to look through the available appraisers index lists (w/ fee reviews.) I’m pretty sure that the $1 appraisal fee across the board short circuits this aspect; day hacks for appraisers having to navigate these systems. Appear at the top of the list!

Remember why these systems were put in place in the first place, which severed the appraisers relationships with lenders, restricted our access to the working space, inhibited our marketing ability, forced us to pay tech fees, drove a hundred thousand appraisers out of business, caused a proliferation of more of these tech systems and amc companies; To support ‘appraiser independence’, and provide better informational security. Who’s still buying this?

Free wrote this, blogs are super slow. Might edit down in an hour or so, probably too long.

YES. What state are you in?

Fantastic idea!!!

Actually there is a magician in New Orleans who could automate the entire process. The same guy who sat up the recent Fake Biden robocall in New Hampshire. He charged $150 for that job…imagine what he could do for appraisers for $1,000.

I do believe in the old saying “no pain, no gain”. Nothing is free in life and sometimes people need to do the right thing to make a point. Sure, it stings but if one can endure the fallout I believe the awards are well worth it. As one commentator pointed out Hawaii did it and it stopped the AMC’s dead in their tracks. Does anyone believe those appraisers didn’t suffer for their cause? Hell yea they did. The AMC’s need to be put on the defense and we have the power to do it but they have intimidated appraisers to the point they think they are helpless. Look it, they are dead in the water if no one will accept their demands. As it is now, rather than coming to the table they have time to scheme and plan ways to exploit us. See this is why we have organizations such as the Appraisal Institute who are SUPPOSED to start these grass roots movements but instead they are licking the boots of big banking and throwing us all under the bus. There needs to be an appraisal organization willing to really represent us. It takes money and we all need to make that sacrifice if we want to be relevant. Anyone out there interested?

My dream site would be hosted by an appraisal co-op that made calls to every US appraiser pretending to be an AMC to inquire about fees. The fees would then be posted online for all to see, thus exposing the deadbeats in the industry.

The AMC and REVAA have been using our Independence against us from the beginning. Dudd-Fwank destroyed our business model and have left us with the crumbs for time, $$ and any resources so the AMC will always be able to find someone who needs to make the mortgage that month, and they have the time and resources to “shop” until they find them – especially now. We missed our window a couple of years ago when things were very busy we had a little leverage – but we didn’t have the time or resources… the State Coalition “volunteers” were bogged down trying to run their own show while the AMC lobby was working full force in DC throwing around $Millions.. WE are not our own enemy – WE have been dealt a horrible hand by our Gubment while AMC’s were handed a Golden Ticket and have been allowed to treat us and the borrower as Chattel since 2009. Nothing will change until we have an advocate in Washington, DC. and it ain’t gonna be Dave Bunton or Maxine Waters. We need HELP from the FEDS!! But be careful what you wish for…. It’s a sorry world we are living in.

I’ve been saying the same thing for years. One has to wonder how someone can actually pass the appraisal exam for certification yet not have the common sense to understand they are destroying their very livelihood. How they can’t see that is so frustrating. Well, I’ll be long gone by the time it catches up with them and then they will have no assignments as they will have driven themselves out of business. The time for unity is now and needed more than it ever. Our industry is known for selling out their mother for $5. but now is not the time or place for that way of thinking. Everyone needs to man up and have each other’s back. Listen to me, that’s never going to happen as long as those mother-sellers are out there.

The AMC’s are doing what they were designed to do; manage the appraisal profession…we as appraisers do not like it but are powerless to do anything about it. Do you think for one minute if Mr Cuomo or someone like him wanted to start a “plumbers management company”, or PMC, or “electricians management company”, or EMC it would ever fly? NO WAY!!! The unions and lobbyists would be all over that idea in a NY minute to end the notion. Our “beloved” Appraisal Institute” has done NOTHING to stop this freight train of deceit, lies, thievery AKA the AMC. We are on our own, get used to the idea ,fellow appraisers, and start looking for new cheese as the book said “Who Moved My Cheese?”, good reading.

Just follow the lobbyists to your state representatives and see what kind of money we are up against. I’m that’s what it is all about, money. They have it in a very organized manor with representation. We do not. This is why it’s much harder to get things to be right with our laws and institutions. The people that make the law may or may not ask the right questions, but they definitely don’t ask the right people.