Portal Fees
Should you disclose portal fees…
Appraisers,
Some of you know that I have written numerous times about my viewpoint that disclosure of the ‘back end’, and sometimes 'front end' portal fees we appraisers must pay to deliver a completed report to a particular client should be disclosed. You don’t have to report the FEE, only that you had to ‘pay a fee’ to obtain the assignment. If you don’t pay the fee, you technically cannot complete the assignment.
My viewpoint has always been, and will remain, that if you cannot technically ‘complete’ an assignment without paying a delivery fee, then the net result is the appraiser should disclose that obligation (not the exact amount paid) in order to RECEIVE the assignment.
Today (11/30/17), the Appraisal Standards Board (ASB) issued a Q&A saying that disclosure of this kind of fee is not required. You can read it here:
They don’t explain what kind of payments MUST be disclosed. The circular logic the ASB presents says that a 'portal fee' is a contractual obligation that DOES NOT have to be disclosed. But you certainly can disclose it if you choose to. No one will fault you for doing so.
I will, of course, wear my heavy gauge suit of armor waiting for broken clipboards, spears and stones being thrown in my direction!
One thing to keep in mind, always, is FAQ’s are NOT technical parts of USPAP. They are opinions only. Their document says so:
“The USPAP Q&A may not represent the only possible solution to the issues discussed nor may the advice provided be applied equally to seemingly similar situations. USPAP Q&A does not establish new standards or interpret existing standards. USPAP Q&A is not part of USPAP and is approved by the ASB without public exposure and comment.”
All my reports are written starting from a pre-written template, (never by cloning a prior report). That template has an Addendum statement about ‘paying a fee’ to RECEIVE the assignment, which I include whenever there is any kind of 'back end' or ‘front end’ fee to be paid when the report is transmitted back to the client. If no such payment is required, like via non-portal direct assignments with reports sent via email, or when using portals without fee payments, then I remove that statement.
As in so much of our work, there are multiple interpretations of seemingly simple-to-understand issues. Appraisers should carefully evaluate all issues, and comply with the intent of USPAP when preparing reports.
Dave Towne on e-AppraisersDirectory.com
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I include the portal fee in my invoice
Ridiculous
Who cares?
Your right WHO CARES?
And why bother to Quote USPAP, what has USPAP done for me lately?
Any fee I include in my report, the buyer/refi person thinks we are pocketing
a lot of cash.
Who cares?
Good point Dave ! I haven’t been including the bogus ” technology: upload, amc rip off fee in my reports but will from here on out !!
I include it as well. I also include appraisal fees in all my reports. I clearly believe in disclosure.
Portal Fees? Guess I’m not working with the “right” companies that you have to pay them to upload a report that they are requesting. And that’s after they are taking half of your appraisal fee in the first place. CRAZY! Or am I misunderstanding what portal fees are?
I build the cost into my overall fee. I was taking to an electrician the other day and asked him about all the parking tickets he accumulates in Downtown Boston, 2 per day at $45 each, he told me he builds it into every job he does there. You want to play you have to pay. Appraisers spend to much time whining about every stupid thing grow some balls and charge for it!
I not only disclose the cost. I also say, “which is the fee the appraiser is required by the client to pay to the client in order to deliver this appraisal which they ordered.”
“Ridiculous”…. should be the response for portal fees not to this blog subject.
I have a wonderful Appraisal Instructor who reminds us almost every class that we are acting as the judge. We are giving an unbiased ruling.
Imagine a lawyer telling the judge they cannot accept his ruling unless he pays a portal fee to upload the ruling! Or imagine a patient telling his doctor he cannot accept the prognosis or the prescription until the doctor uploads it to their computer program and pays a fee to upload it!
IMO, portal fees are one of the biggest disgraces to our profession. If we were truly respected and valued, they would never even think of charging us to send the report that they ordered to them.
Why leave it up to the amc’s to respect us? How about respecting ourselves and not work for these companies that do this.
The portal fee is not a “kickback.” no need to disclose. I have nerver heard of anyone disclosing a portal charge. If you don’t like accepting orders through this system, then don’t.
No, the BS portal fee is another “scam” by the AMC’s over and above what they are skimming off of the American consumer AND the Appraiser Professional. It SHOULD be disclosed. I thank TOTAL transparency is extremely important ! If an AMC’s charged a $100-$300 portal fee and actually paid a REAL ( NON-LOOPHOLE ) state recognized, customary and reasonable fee is it your view that the portal fee should still not be disclosed ? I wouldn’t put it past them. Are you saying that the fees AMC’s collect other than portal fees ARE kickbacks ? Hmm, maybe they are !!!
Why leave it up to the amc’s to respect us? How about respecting ourselves and not work for these companies that do this.
I think a few states require disclosure in the report. Unfortunately the two I work in do not, but that doesn’t mean this information can’t be included anyways.
I also start with a pre-written template. Dave – would you mind sharing your statement about paying a fee to receive the assignment?
Disclosure is relevant. What is relevant about disclosing fees in a valuation report on any property or item. If it is a residential property the mortgage lender is responsible for supplying the purchaser a TILA. That should cover everything about the cost of obtaining a loan including appraisal fees. Are the lenders completing their due diligence? Are THEY including AMC FEES in the TILA? When you get an assignment are you being supplied the TOTAL FEE THE AMC IS CHARGING? Inequity abounds. Until the appraisal industry has solidarity and has a seat at the table of decision in our industry we all must bend over and take it.