Appraisal Regulation Compliance Council Exposes Disturbing AMC Violations

Appraisal Regulation Compliance Council Exposes Disturbing AMC Violations

The Appraisal Regulation Compliance Council published a detailed breakdown to the CFPB, which showed the median average AMC fee being charged to borrowers amounted to a staggering 65% of the total appraisal fee, with one AMC extracting as much as 84% in pure profit.

The Appraisal Regulation Compliance Council (ARCC) is a crucial non-profit organization that specializes in providing fact-based research and expertise on the complex web of appraisal regulations and compliance issues. Driven by a non-partisan mission, ARCC has spent the last two years diligently collecting, vetting, and organizing comprehensive data on lender appraisals conducted by Appraisal Management Companies (AMCs). Their meticulous research has uncovered a disturbing pattern of violations of key regulations intended to protect consumers, including the Appraiser Independence Rules (AIR), the Uniform Standards of Professional Appraisal Practice (USPAP), the Truth in Lending Act (TILA), and Title XIV of the Dodd-Frank Act. Alarmingly, these violations are often disguised under the pretense of a so-called “firewall” that is meant to safeguard appraiser independence.

ARCC’s findings reveal how the existing Integrated Disclosure forms used under TILA and the Real Estate Settlement Procedures Act (RESPA) have created perverse incentives for AMCs to inflate their fees without any corresponding improvement in appraisal quality or timeliness. In fact, many AMCs seem to treat appraisal quality as a low priority, directly violating the provisions of TILA, Section 129E. The hidden fees collected by these AMCs appear to be primarily for the purpose of unjustly enriching themselves, price gouging consumers, and failing to fairly compensate the licensed appraisers who bear the majority of the risk.

To substantiate these concerns, ARCC recently published a detailed breakdown to the Consumer Financial Protection Bureau, which showed the median average AMC fee being charged to borrowers amounted to a staggering 65% of the total appraisal fee, with one AMC extracting as much as 84% in pure profit.

ARCC exhibit: AMC fees breakdown - price gouging

Deeply concerned by these practices, ARCC has called for a comprehensive, in-depth investigation into the rules and regulations governing appraisals, AMCs, and the broader lending industry. As a trusted, non-partisan research organization, ARCC’s work is invaluable in shedding light on these critical issues and empowering both consumers and policymakers to navigate the complex landscape of appraisal regulations. Ensuring transparency in AMC services is a critical matter that directly impacts the safety and soundness of the entire mortgage industry, as appraisals exist to protect the soundness of our banking system and the interests of consumers – a responsibility that ARCC is determined to uphold through its rigorous, fact-based research and advocacy.

Click here to learn more about the Appraisal Regulation Compliance Council.
 

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96 Responses

  1. Avatar Anthony D Zazueta jr says:

    AMC’s have been a pure “for profit” industry since they were established. Cheapest appraisers are getting all the work. These places have a department dedicated to finding the appraiser who will do it the cheapest and fastest regardless of quality. I reviewed for one of these companies and witnessed quality so terrible that I recommended not using certain appraisers because they simply didn’t get it. The company wouldn’t stop using them because they were willing to complete appraisals for $200 and turn them in within 48hrs.

    7
  2. Baggins Baggins says:

    The old ‘preferred appraiser’ routine and ‘performance grading’ are flimsy pretenses to cover for preferential assignment in order to avoid complying with AIR rules. Independent professionals get graded out of their positions and told to comply with unreasonable performance expectations.

    The amc industry circumvented the intention of AIR rules with several key approaches. 1. Never assign orders equally to all panel appraisers. 2. Use grading as an excuse to silently blacklist appraisers whom do not play ball. 3. Never honestly inform appraisers they have been virtually removed from active order participation or were somehow segregated to only complex work other discount appraisers would not accept. The approach is so popular, many direct assignment lenders whom do not use amc’s, now also utilize a similar operational practice of biased disproportionate order assignment.

    All that is necessary to form better appraisal independence modeling, are requirements for all approved appraisers on any given lender or amc’s approval panel, to receive an equal amount of work in a rotational assignment que. (faster you turn them, faster you get back in line for another, aka round robin.) And consistent fees to all appraisers receiving assignments. Also separated amc billing, as the amc’s do not provide appraisals, and should be billing for the management service separately. Pressuring appraisers works, and works very well.

    15
    • Avatar Brett says:

      also — conveniently remove docs from appraiser profiles (i.e. “missing licenses, E&O, etc.”) to effectively remove them from assignment eligibility -> and has same censoring impact (versus having to legally explain why an appraiser was ‘removed’ from a panel… i.e. for doing their job correctly, disclosing, etc. vs “not playing ball” and being blamed for a loan not closing, delaying LO payout, etc.)

      0
  3. Avatar Eric Kretz says:

    If we can’t accept that AMC’s are the enemy, we deserve everything we get. The bidding and accepting these fee’s is a race to our AI and AVM replacements.

    Any appraiser that accepts a full 1004 assignments for $125 is pants on head absurd. You’re actively killing the appraisal profession, and running other good appraisers out, full stop. We are our own worst enemy, and until we realize that AMC’s are bottom feeding off starving appraisers they will continue to offer insulting fees.

    This isn’t 2005. Like Bags said, don’t give in to the pressure. Know your worth, know what your costs breakdowns are, have some pride, and get yours.

    12
    • Baggins Baggins says:

      The kick in the pants will be if amc appraisers are rewarded for all these years of complicit knowing participation in consumer fraud and get fee raises for their sub par amc work. I’m with PDM on this one; a total dismantling of the amc industry. Force rotational assignment nationally for all appraiser panels. Re adopt the missing component of HVCC that if an appraiser is to be removed from panel (or active rotation on the panel), the appraiser must be notified of the exact reasons in writing. Consistent fees and volume for all approved appraisers on panel for all routine assignments. If an appraiser is good enough to be placed on an approved appraiser panel, they should be able to expect consistent fees and an equal volume of work. Go back to the old model where there was a fixed billing relationship where 100 % of the exact amount the individual consumer paid for appraisal services, went to that individual appraiser completing the task. No more improper co mingling of fees and funds.

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

      7
  4. It’s frustrating but not surprising to see the ARCC’s report highlighting how some AMCs are taking up to 84% of the appraisal fee. This isn’t just unfair to us as appraisers but also to consumers who are being overcharged without seeing any real benefit. AMCs were supposed to protect our independence, but instead, they’ve turned into profit machines that ignore quality and fairness. We need to push for real changes that ensure fair compensation for appraisers and transparency for everyone involved.

    11
  5. Avatar Scott says:

    I just realized i spend more time converting appraisals to computer gibberish than on the appraisal.

    5
  6. AMC = “Appraisal Middleman Con”

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    • Avatar Frustrated Appraiser says:

      (Most not all are) AMC= As*shat Micromanaging Cheapskates who harm consumers, appraisers, our banking system and could be harming our economy too.

      11
  7. Avatar Jason says:

    Anyone else want to move to Connecticut? But seriously, these AMC actions are disgusting.

    5
  8. Avatar PDM says:

    After billions of consumer dollars in over-charging and loss of income to appraisers, this could have easily been discovered had the appraiser been allowed to include an invoice with the appraisal or disclosed the cost in the context of the report. The AMC industry all said no, you can’t do that Mr. appraiser (otherwise the dirty little secret would get out). This in itself was a huge red flag. This is on the government institutions who have failed in their fiduciary responsibility to protect the general public from such egregious acts of greed. Everyone has been so hell bent on pointing the finger at the hen (appraiser), they forgot, or purposely didn’t look at the fox. The current process has been proven to be riddled with greed and needs to be scrapped. AMC’s need to be dismantled, just like what they are attempting to do the appraisal industry and return to a system of monitored checks and balances. In 40 years as an appraiser the industry is more screwed up than any other time in history and not at the behest of the appraisers themselves, I might add. The system has gotten far too complex leaving the door open for culprits like the AMC’s. Appraisers should not be at the whim of an AMC as to what they are paid, being graded unjustly, being beat-up on price and the list goes on (much of which is illegal as stated in the article). These are the same people who are screwing everyone over for heaven’s sake and have little to no morality of conscious. Yet, someone thinks it’s a good idea to put them in charge of appraisers? BS. This article proves it is simply a cash-cow to them and they are laughing all the way to the bank. Ya know, every day we read of attorneys and doctors doing the unspeakable to their clients, yet they don’t have a middleman to protect everyone’s well-being they report to and negotiate fees with. (Perhaps they should have their own form of AMC tailored just for them also?}. Nope, only the appraisers do. Sound unjust, yes, it is. Again, the AMC’s have squandered their usefulness as they have proven they are not trustworthy and are selfish opportunists. They can’t be trusted with 10 cents let alone an entire mortgage industry. This should be grounds for a complete revamping of the system and elimination of AMC’s.

    18
  9. Avatar Kevin says:

    Yup, one of the ones in oregon I submitted. I clearly relember the shock of that order, especially when I do direct work for the cleint there were apparently “helping” These are the worst offenders of this, clearly. All collusion to get the maximum profit to keep their AMC afload in the downturn of real estate activity.
    Ohh and now NFHA and HUD are putting up billboards and signs in airports about “appraiser bias” .

    7
  10. Avatar Mike Irvine says:

    Great job Josh. I think it would be a nice piece of data if somehow you could report what the median fee paid by the consumer was prior to AMC’s in comparison to what the median fee is now. In addition to the ridiculous profits, AMC’s are now charging consumers considerably more pre Dodd Frank and HVCC. Basically AMC’s are not saving consumers money, in fact, consumers are paying more.

    8
  11. AMC’s screw Appraisers and we are blamed for higher fees. This profession has been a tail wagging the dog for decades. It has and is destroying public trust in our profession. Hello retirement coming very soon. Can’t come soon enough. So sad to end it this way.

    7
  12. Avatar Disillusioned business owner says:

    Am I understanding that the ARCC is looking to govt individuals to rectify a problem that govt created? If govt cared they wouldn’t have created AMCs in the first place. I guarantee that every AMC can be tied back to someone in govt who voted for this to occur. “I’m from the govt, and I’m here to help.” Same thing, different decade. This story and the data are presented well, but I don’t see the cause being the solution. Good luck.

    4
    • Avatar PJTC says:

      AN APPRAISAL FAIRYTALE –
      The purpose of the AMC was an effort to separate the “bad” appraiser from the lily white mortgage brokers. It was just another situation and as always it was the bad appraisers fault. They believed this was the solution never counting on the AMC’s to become the bad middlemen. With no real oversight on the AMC’s bad players showed up and wanted their fair share. Seeing the AMC’s were ripe for picking, they set-up shop. They found ways to hide their devious plan from everyone. Appraisers were being told, in a suttle way of course, to not complain or they would get the axe. The dutiful appraisers, being afraid of not being able to put food on the table, fell right into shape. Once they got the appraisers in line they came up with this great idea of pitting appraisers against one another by putting assignments out to bid. This was a hugly effective move because they could use the lowest bidder, tack on the addional appraisal cost then jack the whole tidy package total up to 60, 70 80 percent. Oh, they thought, we are so clever. We are not only screwing the appraiser, we are screwing the consumer and no one has a clue. We are protected by the US Government who hasn’t a clue of what we are up to because of course we are the golden boys beyond reproach with no real oversight. HaHaHa, this is brilliant as they were patting themselves on the back. But then, when appraisers finally were fed up and being attacked from all angles, they actually started speaking to one another about how they are made out to be he criminals while all the time it was an industry they knew were the criminals violating the law and overseeing them. But foolish regulators did not want to hear what the front line bad appraisers had to say because they are untrustworthy so they went to the lily white AMC’s for feed back. Unknown to the AMC’s a new Sheriff was in town, Sheriff ARRC. Which leads us to today. It will be interesting to see what the regulators do about this “misunderstanding”. There will be a lot of finger pointing and I’m sorry, didn’t mean any harm, we all know how it goes. Don’t be surprised if in the final outcome somehow the racist, biased bad appraisers are all to blame. The end. I hope you enjoyed this brief fairytale.

      8
      • Avatar Eric Kretz says:

        In 2007, HVCC rolled out and many mortgage companies (big and small) found a workaround and very profitable solution by creating their own AMC to funnel their mortgages. They discovered that not only could they continue to control the entire loan process start to finish, but could be very profitable and market to other users in need of an AMC.

        I can name two here in CO that did exactly that.

        A large mortgage company hired a 3-person team to set up an AMC from their mortgage loan production staff. It was constructed as a separate LLC, and on the surface appeared to be completely above board. This was a good client that was on a rotation style panel. Overnight, they then went from paying $375 for a full 1004 to $250. A lot of starving appraisers were forced to take these fees due to the slowing market. Appraisers were told the decrease in fees was for the AMC, shut up and be happy you have work.

        Then the phone calls started from the borrowers inquiring why they were getting charged $750+ for their appraisal.

        The only real recourse since then was Colorado HB 12-1110, which states the appraiser must disclose in the appraisal report the fee paid to the appraiser for a residential real property appraisal, if the appraiser was engaged by an AMC. All this did was confuse and anger the consumer who didn’t understand who the AMC was, or why they are needed, and why did they get charged more for an appraisal.

        Starve the AMC’s, and choose your clients wisely, get paid what your worth.

        6
        • Avatar Pat Turner says:

          What we need is to make a separate addendum page called APPRAISAL FEE DISCLOSURE STATEMENT!

          Make it a separate and distinct page of the report.
          If anyone demands you remove it….. Bingo!!!! Violation of Appraisers Independence!!

          And it more accurately illustrates what the hell is going on!!!!

          3
      • You win best seller of the year. Oh how sad, but oh how TRUE! This fairy tale is Fact not fiction. Good job! ?

        2
      • Baggins Baggins says:

        PJTC, All true. They got greedy, took too much. As I like to say on this blogs; amc’s don’t want just a cut they want the entire pie. Their lack of oversight allowed workarounds and market capture in more than just the valuation space too, they used the surplus funds taken from the appraisal industry to enter into several other industries related to mortgage lending as well.

        Probably not a coincidence that Corelogic bought Alamode and subsequently was able to pressure them to shut down the AA Appraisal Advisor program briefly before that period of amc industry capture of the majority of appraisal requests from lenders. As appraisers may recall, the AA program was specifically for appraisers so we could network and provide reviews about amc companies among each other.

        ARCC if they wanted to expand the scope of services could also create a publicly searchable database by all appraisers, where we could review all types of clients whom send appraisers orders.

        Found this one on the way back machine a while back. I was trying to find those same functional pages that AA had put up as the first rounds of appraiser client reviews were coming in, then it was all shut down almost immediately. Appraisers were waiting in line to sign up and were really inspired by the concept.

        When is the amc industry going to finally be audited? If the original spirit of Dodd Frank Reg Z on Customary and Reasonable market rate billing was upheld with the $10k/$20k daily recurring fine for amc’s acting as agents of lenders, this has the potential to be the largest class action in American history.

        2
        • Baggins Baggins says:

          Another AA photo.

          1
          • Avatar kevin says:

            Site does not work, must be old stuff or not active.

            0
            • Baggins Baggins says:

              Of course the site does not work. There was so much industry pressure the effort was shut down from the top down. Appraisal Advisor was the idea of the son of the founder of Alamode, Biggers. He wanted to provide a truly useful tool to help appraisers because it was obvious then how exploitative the amc industry was becoming. Right when the site went live within a month or so, there must have been so much pressure that they shut the effort down. If memory serves shortly there after both Mercury and Alamode systems were sold to Corelogic. Many appraisers paid into the sites development like a kickstarter type campaign. People were interested. There were long lines to sign up. The initial amc reviews were alarming.

              1
        • Baggins Baggins says:

          And another. That’s all I have, three images. Wished I would have saved some of their site data. Anyone else have old records or material from AA?

          2
        • Yes I do remember that service and it was short lived. I think a class action suit would be so awesome and a good case to win! they should pay all Appraisers for billions in lost revenue. Who can we hire. I am on board.

          2
    • Avatar Josh Tucker says:

      Unfortunately the government write the laws. They are the only once who can fix their mistakes. But, we also are not operating the way we have in the past…..oh no. We are going public with evidence so it can’t just be swept under the rug and hidden. We have a lot of fun plans for what we will be investigating, compiling, and presenting to the public, regulators, and officials.

      8
  13. Avatar NJGatorChris says:

    I sent the report to my Congressman….maybe a politician trying for reelection would welcome the publicity and gain some fame? Maybe we should all send in the report to our Representatives in Congress?

    5
  14. Avatar sb says:

    its OBVIOUS what’s fueling all of this BULL SH*T are AMC kickbacks to lenders.

    THATS THE DIRTY LITTLE SECRET

    Why would any LENDER put up with this otherwise long term?

    We need to hire the same Attorney that busted up NAR.

    We are entitled to MILLIONS in lost compensation.

    IF Y0U VOTE FOR KOMRAD KAMALA YOU CAN KISS YOUR APPRAISAL CAREER GOODBYE

    12
    • Avatar Pat says:

      We are in contact with that law firm

      7
    • Retired Appraiser Retired Appraiser says:

      What does Kamala Harris have to do with the hijacking of the appraisal profession (which took place in 2009)?

      Answer: Nothing. There is a cure for TDS (Deranged Trump Syndrome)… it’s called prison.

      Anyone who didn’t kiss their appraisal career goodbye in 2009 has obviously been living off of a trust fund or mooching off of a spouse.

      3
      • Avatar Pray Hard says:

        Leftists destroy everything. That’s why.

        10
      • Avatar Eric Kretz says:

        Not taking sides, but it’s glaring obvious that the current administration has gone out of it’s way to kill the appraisal profession in any way possible, starting with HUD and their DEI initiatives and continuing through the NFHA. If you haven’t read all the AB articles here you’re not paying attention or just ignorant.

        However, the fact that you’d like to see citizens jailed for the political beliefs speaks volumes about you.

        There must be nothing better to do in retirement than sit around and complain about your old job and shout at clouds.

        14
        • Baggins Baggins says:

          For a minute I thought sanity had returned and he said the cure for TDS. Like having finally gone through some personal effort to consume less fake news propaganda. Nope. He’s still hooked in.

          Retired, want to play a game?

          7
          • Avatar PJTC says:

            My, my, my. It would appear Baggins has struck a nerve. There seems to be a very bitter, angry person in our midst. I’m kind of enjoying what it brings to the discussion.

            1
            • Baggins Baggins says:

              Retired is awesome, he gives good advice now and then. The problem with major parties these days, the corporate media apparatus they wield no longer objectively reports in a fair or impartial manner. Rather through consistent repetition and constant messaging, they prescribe peoples beliefs for them.

              There are some things the politicians and bureaucrats always agree on. Taxing you more and spending more of your tax dollars. Justifying their jobs and an ever expanding growing government to remain in the life of luxury. Supporting corporate welfare. The revolving door.

              Many licensed appraisers are acutely aware of the failures of government. Because our individual rights are violated every single day we attempt to carry on in this industry. The irony of the ethics update focusing on protected characteristic. While our own federal government and supportive non profits accuse us of intolerable behaviors, simply because we are white.

              Let’s see, which Ron Paul quote would work best here… I’ll go with the simple one about principals. Because that’s what we’re talking about when talking about the amc industry. An entire industry brought up around a complete lack of ethical principals. Where is the justice?

              2
        • Retired Appraiser Retired Appraiser says:

          I didn’t start with the politics pal. Ding ding above started blaming Harris of all people. Why not blame FDR?

          For your information, politicians didn’t tank your profession… appraisers did. I chose to walk away rather than be extorted. The guys who agreed to keep appraising for beans (Yes you) are the ones who allowed AMCs to hijack the industry. Yes I enjoy shouting at clouds (aka LAZY ASK appraisers) for pi**ing away their profession. Cry much?

          2
          • Avatar Eric Kretz says:

            RA,

            First off, I’m not your pal.

            Second, for you to summarily blame appraisers part and parcel for the current state of the industry is delusional ignorance. HVCC, Frand-Dodd, Fannie and Freddie and big gov’t regulations had zero effect on where we are now? Jeremy Baggots articles are the receipts and have outlined this in detail for years. But sure, it’s all the appraisers fault.

            Third, I don’t appraise for ‘beans’. My average appraisal fee last month was $647. I do well because I actually have the balls to charge what I’m worth and do business with good clients who value my work. A good number of appraisers are doing well enough to not throw in the towel. (not yet anyways) As much as I complain here on the Blogs, I’m still fighting, email my congress-critters, and stay active locally doing what I can. You just quit.

            Maybe you were a bad appraiser, maybe you just ran your business poorly, who knows. You leaving the industry bitter and broken doesn’t imply all appraisers are walking your failed path.

            I’m not crying, I’m actually laughing at you. After all these years you continue to come here and spew your redundant mindless drivel. I dunno, maybe pickleball could fill the void for you instead of insulting good appraisers and wishing to imprison people who don’t think like you politically.

            Good luck man.

            7
            • Avatar PJTC says:

              AHA, Eric. I stand corrected. You are the one who obviously struck a chord. Unlike the unwarranted attack on you, you are the voice of reason and your response is spot on. There will always be those that can’t help being angry and miserable, always seeing the glass half empty. They always bring lively banter to any conversation but given no real relevance. The “attack” was only intended to be inflammatory in such a way as to question who is and is not disguising themselves as an appraiser on the blog.

              1
            • Retired Appraiser Retired Appraiser says:

              Congrats on your 4 plex orders each month…both of them. Considering the scope of work required today $647 is beans in my opinion even if it’s a 800 SF home. Just so you know…Pal you might want to leave your politics at home the next time you post.

              1
              • Avatar Eric Kretz says:

                Sure thing….. you’ve now just proven you’re nothing more than a childish troll and this site should ban you for being a clown.

                I’d love to keep teeing you up, but I’ve got much better things to do with my time.

                What do you say RA, time to go somewhere else?

                3
              • Avatar Pray Hard says:

                Thirty five years ago, I was getting $500 for a duplex/fourplex. I’ve stopped bidding them now because I can barely squeeze out $400 with these AMC’s.

                0
      • Avatar JM2C says:

        Harris has repeatedly cited anecdotal reports from homeowners of color who received low appraisals, using this as evidence of widespread and systemic bias in the appraisal industry. In essence, Harris argues that racial bias, both conscious and unconscious, is prevalent among white appraisers.

        https://youtube.com/shorts/8nD2HzoYylY?si=6GJhd5hrDjX44yaR

        11
        • Avatar PJTC says:

          I just love watching politicians who have no clue of what they are talking about and rely on main stream media for their ignorant analysis. The woman has painted all appraisers with a broad brush perpetuating and promoting racial bias in her own best political interest and the sheep blindly follow. No political statement being made here. Just an irrefutable observation of a politician who is part of the gang attempting to disband the appraisal profession. Making it political in nature rather than what it is, is the first line of defense for those sheep who have lost their way. The clip speaks for itself.

          6
    • Avatar Jeff Boyd says:

      Totally Agree!!! No one could convince me that all of them are getting some sort of “kick back”. Dodd Frank was a junk piece of $#@! Legislation, and never intended to be regulated by the powers that be.

      1
  15. Avatar Larry Fuller says:

    SO Why are you surprised??? Again what are WE as an industry going to do about this? …TALK???

    1
    • Retired Appraiser Retired Appraiser says:

      Yep..What else are appraisers capable of doing?

      0
      • Avatar Flash says:

        Appraisers who have dual licenses don’t need AMC’S.

        RA you quit way too soon and did not see The Forest for the Trees as for ways to make money.

        As a Real Estate Broker owner and Certified Res Appraiser I really like Inherited Homes for estate appraisal work. After the appraisal is delivered, if the estate likes and trusts me, I list and sell their estate property.

        In escrow, I disclose to all parties that I have provided prior services for full disclosure. So there is no conflict as to appraiser / broker representation. It’s that simple.

        So if I list a n estate property for $1.5 million there is over $30k+ commission for me and a couple of those properties a year, I only do less than 20 appraisals a year.

        99% of my work is legal, non lending work. The 1 % of AMC work is Nothing but the Rush 48hr where I charge ridiculous fees in Silicon Valley when the AMCS are backed up over 3-6 weeks or more.

        When the refinance boom starts next year appraisers should be busy and my rush work will also be needed.

        2
        • Retired Appraiser Retired Appraiser says:

          I was a broker as well. Left both for greener pastures. People assume that I am completely retired, I am not. I just left the extortion racquet. We lost around 150 clients overnight in 2009. I had no interest in rebuilding the business based on a 50% fee cut. It wasn’t a wasted 20 years however; I have always made more money flipping houses than we did in the brokerage and valuation businesses.

          1
        • Avatar PDM says:

          That seems like a fine line is being crossed. You are doing an appraisal on a house you are hoping to obtain the listing for? Not being critical, just making an observation. It would seem this has the “appearance” of impropriety written all over it. Just curious, have you run this by anyone to see if you are in the clear with this? I would be interested in knowing. Thanks.

          3
          • Avatar Flash says:

            Again. Full Disclosure. In escrow to both parties. I don’t attempt this with any prior appraisals done for AMCs because that would be a line crossed. Since I am doing non lender work with estates, who contact me directly, there has been no line crossed . When talking to clients I first explain which hat I am wearing at the time of each discussion. I am a Broker Owner and own my own appraisal company. That’s probably the only way to do it. That’s my business plan in a nutshell, what have you got?

            0
            • Avatar PDM says:

              Whoooa Silver, please read my question over, I am not being critical or attacking you just seeking some insight into your process. There is no sarcasm necessary. It was a reasonable question to your situation regarding any guidance you might have received. Perhaps from a legal professional. There was no intent to offend you.

              1
              • Avatar Flash says:

                I have not even drawn a weapon from my holster. Have had a real estate license before an appraisal license since 1980 to the present. Too many prior live appraisal instructors were unclear as to having two licenses. Even uninformed lender reviewers many years ago attempted to claim that there was a conflict of interest just having two licenses. I had to threaten a review company to show where it is a Conflict of Interest for an appraiser just to have two licenses. For years I have mentioned to appraisers to get both licenses and move toward non lending work. If you search online across the nation, there are appraisal businesses with brokers licenses for years.

                0
              • Avatar Flash says:

                When I upgraded my Real Estate Salesperson license to Broker it was over 360 hours of courses that protect the general public. In taking the actual Broker test, I sat for two three hour periods of morning and afternoon going over the test which was 80-90 % Real Estate Laws to protect the general public. Full Disclosure is the key with clients and I refuse to double end real estate commissions again to avoid improprieties or other areas of suspected Conflicts of Interest with my actions. Furthermore, I willingly promote my services as a Real Estate Appraiser Expert Witness for lawyers and estates in the court room.

                0
  16. Avatar Pray Hard says:

    Seriously, who didn’t know that the appraisal industry was being degraded/destroyed from the get-go when this so called “firewall” of AMC’s showed up? It was nothing but a financial scam/extortion from the beginning.

    9
  17. Avatar Mat Just says:

    Such greed with these AMC‘s. 84% gross profit margin is ridiculous. Most people don’t care about the Appraiser but this is ripping off the consumer and the appraiser.

    7
  18. Avatar JM2C says:

    This failure to act has enabled AMCs to continue raking in windfall profits, all while appraisers struggle with stagnant fees and borrowers are forced to shoulder the burden of these inflated costs. It’s high time for the regulators to step up and fulfill their duty!

    7
  19. Avatar steve says:

    Shane is fighting back ..if there is any doubt read his recent court docket entries…

    2
  20. Retired Appraiser Retired Appraiser says:

    IF this is a moderated web site why is it not possible to delete all posts which make reference to one’s political preference? If politics are fair game let me know, I will submit an article a week regarding Trump & Company.

    I am also curious why everyone assumes I am retired and feeble. I work 13 to 15 hour days in endeavors that are actually profitable; hence, no more appraising.

    Consequently, if old age really is a reason to look down on someone you guys certainly picked a decrepit loser as a presidential candidate. Send him to the bone yard.

    2
  21. This blog’s moderation policy reflects a thoughtful and balanced approach to facilitating open discourse, prioritizing the free exchange of ideas over heavy-handed censorship. The moderators recognize that meaningful dialogue requires the airing of diverse viewpoints and perspectives, rather than simply deleting posts based on their political leanings or ideological alignment. Even comments containing profane language are not immediately removed, but instead have the offensive content edited out, preserving the overall message and intent. The only comments that are fully deleted are those deemed to be clear-cut spam, ensuring the forum remains focused on genuine discussion, debate, and the exchange of ideas.

    The moderators actively encourage readers to engage respectfully with one another, even when they fundamentally disagree with the opinions or perspectives being expressed. Rather than resorting to personal attacks, name-calling, or other toxic behaviors that can quickly derail a constructive dialogue, readers are urged to challenge ideas and viewpoints in a civil, measured manner. The goal is to maintain a professional, courteous atmosphere akin to what one might find in a workplace setting or formal organizational context, where disagreements are aired through reasoned arguments rather than inflammatory rhetoric. Snide, rude, or unconstructive comments that do little to further the discussion are to be avoided, as they can serve to alienate other participants and detract from the overall quality of the discourse.

    It’s important to recognize that politics and policy assessments are inextricably intertwined, making it difficult to have a nuanced discussion about appraisal-related issues without also addressing the underlying political context. In this case, the Biden administration has been quick to blame appraisers for declining property values in marginalized neighborhoods, even going so far as to label them as complicit in perpetuating systemic racism. This highly charged political environment has understandably led many appraisers to distance themselves from the current administration and the Democratic party, who are perceived as unfairly targeting their profession.

    The moderators of this blog remain committed to fostering a space where these complex, sensitive issues can be explored and debated in a thoughtful, evidence-based manner, with the ultimate goal of promoting greater understanding and finding constructive solutions.

    We encourage all to remain focused on the subject matter and to submit any evidence of AMC violations to the ARCC at cfpbevidence@gmail.com.

    8
    • Baggins Baggins says:

      Oh yeah. There are some fundamental disagreements here.

      That should not stop us from working together on such an important cause.

      3
  22. Avatar PJTC says:

    What’s with all the hostility. It’s at the point of ridiculous and counter productive. No need for it. If no one has anything to contribute in a meaningful manner why are you here?

    1
  23. Wow, a lot of unneeded hostility. Now back to the Fee thing. If you total the amounts of the 33 fee examples in the provided document, the total paid out by lenders (actually borrowers) is $37,243. Of that, the AMCs received $21,505.93 (57.7%). The appraisers received a mere $14,601.87 (39.2%).

    So… $37,243 is only 33 appraisals. ARCC stated this is only the tip of the iceberg with regard to the data collected, representing about 10% of that received.

    The Federal Housing Finance Agency (FHFA) published the 2024Q1 update of the Uniform Appraisal Dataset (UAD) Aggregate Statistics Data File and Dashboards on June 27, 2024. The UAD Statistics reported 673,088 appraisals being provided in the 1st quarter of 2024.

    We can expect that a large number of those appraisals were generated through AMCs. So… Yes, the AMCs are making a killing off the backs of the borrower while the appraisers, those with all the liability, are getting hosed!

    And the regulators – well… Crickets.

    4
  24. Avatar Paco Murray says:

    Having done many appraisals for Class Appraisal in the past, they suddenly turned off the faucet with no communication whatsoever. After reading these articles above and seeing the many posts from appraisers, I’m kind of glad Class disappeared from my radar. I do not want to work for crooks.

    6
  25. Avatar Pray Hard says:

    Another big problem with the AMC’s is having to get caught up in their incessant chaos. It was bad enough when we dealt directly with lenders, but the AMC’s take the cake on wasting our time. I’ll get a bid. I’ll research it and the market, spend a morning doing those things. I’ll bid on it. Won’t hear back. Then days later, because, you know, time is of the essence, they say that they accepted my bid and will I send them a new due date. I send them a due date commensurate with their delay and I don’t hear from them again. I typically could have already had the appraisal finished but for their screwing around trying to “save” $25. Maybe 1% of the bids I get are of normal-ish properties with adequate comparables. The other 99% are rural, on busy streets or highways, back up to gas wells, commercial, apartments, have add-ons, converted garages, structural problems, poor maintenance, are commercially zoned or if they are updated, remodeled, etc., they didn’t get permits. Then there’s the comparables issue. Most sales are vastly overpriced relative to the competing market, typically anywhere from 10% to 40%. I always hear about a housing shortage and I drive around seeing vacant, developed, probably foreclosed on, subdivisions with not a single house being built. Sometimes, there’s one sale that appears to support the subject sale price, but it was from 12 months ago, had $10,000 in seller paids and sold for $40K above the list price. But, hey, DEI is our goal, right?

    1
  26. Avatar Pray Hard says:

    Hey, did any of you guys ever do appraisals for AAA Appraisal Advantage out of California? They left me holding a $400 hot check two or three years ago and now appear to be in oblivion. Just wondering.

    0
  27. Baggins Baggins says:

    What’s happening with this? Any updates? Mr Turner, how can beleaguered appraisers join in a class action effort?

    1
    • Avatar Kevin says:

      We can all just send a copy of the letter and expose’ to all of your lender clients and realtors that you come into contact with. It has been my esperience that 95% of the ones I talk to have not heard anything about what is happening with AMC’s and the jacking of fees that is going on. And when they do find out they are pisssed!

      2
    • Avatar Pat says:

      Can you give me a call

      1
    • Avatar Josh Tucker says:

      ARCC is a Research Institute. Nobody can speak for them except through ARCCs webpage itself or posts from their LinkedIn. They have a lot of projects they are working on and a fun announcement coming up. Rest assured they are not staying idle.

      2
  28. I finally announced my retirement to the masses what a load off. Between Bias, AMC’s, ROV, NAR Lawsuit, the new appraisal form coming out, now is the time to bow out after 30 years. The more I think about this BS the more I now understand we have been ABUSED for decades. Class action against AMC’s for mental and financial abuse is in order and we need someone to take it on. This could be the largest class action suit ever, worth billions. Let’s bring it on! Come on good Lawyers out there this could be a career changer! Good luck all and I will keep watching. I emailed all my Realtor contacts (300+) and I have tweeted to Kamala and media sources all about why after 30 years I felt the need to retire early due to the destruction of a profession and that it needs to be understood and fixed or it will be very bad for those they are trying to help! Crash and burn comes to mind. God speed everyone!

    3
  29. Baggins Baggins says:

    Wow. Look what I found quite by accident in old emails, dated 01/15/2014. Appraisal Advisor.

    They were creating a counter database of appraiser only reviews. A database of what everyone was paying appraisers. This would have allowed better paying companies to compete for appraisers, rather than appraisers being forced to compete in the blind among each other. In retrospect, this effort would have ended the $20b+ amc fraud in the early stages. They were also integrating Appraisal Advisor into the Alamode software itself. Alamode on the other side was publishing yearly fair fee surveys by parsing all the Mercury data and specifically excluding amc fees. Then although many thousands of appraisers signed up for access, not enough were paid subscribers, and they shut the effort down due to lack of funding. Check your old emails; appraisaladvisor / without a space.
    https://twitter.com/AppraisAdvisor

    1
  30. Avatar Pray Hard says:

    How did it get to “everything is about the appraiser”, “everything is the appraiser’s responsibility”, “why are you calling us”? I ask the AMC if a month old bid is still active? Just had a three or four week old bid cancelled12 hours prior to inspection appt. Appointment changed three times by borrower. “Was it your idea change the inspection time Mr. Appraiser”? Yeah, sure, that’s what I do, you know, just to create confusion and contention. They don’t contact the lender and get an answer to the question. They tell me to call the borrower. Maybe I should call the lender and cause a critical mass explosion. I’m sure some of you guys remember the day when you got an order, called the contact, set it up and did it, no drama. Now, it’s at least 75% drama. Furthermore, when did it become the appraiser’s job to close the loan deal for the lender by convincing the borrower that they have to get an appraisal?

    0
  31. Avatar Scott says:

    The AMC was almost laughing about a rush order that was cancelled just before I was at the door and was going to stiff me. I called the lender and they had collected a deposit and they said no one should have to work for free.

    2
    • Avatar Flash says:

      Good for you. I have had assignments canceled after 1 day of inspection by an amc yet I was paid in full immediately for the assignments . Or else I would put a Mechanics Lien on the property with the county and stop the loan until I was paid in full plus costs of adding and removal costs of the lien.

      As an independent contractor appraiser, you have every right to add a Mechanic Lien when people play games with an appraiser and their time.

      If I have inspected a property, the full appraisal fee is due whether it is canceled.

      2
      • Avatar Frustrated Appraiser says:

        Not all states allow mechanic’s liens. Also should be filing a complaint with the state too.

        1
        • Avatar Flash says:

          The National Lien and Bond Company has a two minute online help page for all 50 States.

          There is either a Notice of Intent to file a lien or Notice of a filed lien.

          Hopefully this will help readers to understand which state and the process of defending your work if needed.

          It’s really an easy process and strikes fear in a management company, lender or escrow company should the appraiser lock up a loan process due to an unpaid appraisal.

          Years ago I would sometimes extend credit to homeowners who claimed they did not have the money to pay for the appraisal upfront.

          The borrowers who took advantage of my kindness were surprised when the lien notice appeared in their mail box when they thought they had ripped off an appraiser.

          1
  32. Avatar Albert Vernon says:

    This is very Good stuff and one that is good for freedom of speech. It is nice to know that there is a platform where appraisers can vent or even rant on issues other than the appraising of real property. This certainly can help to broaden the horizon of appraisers.

    1

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Appraisal Regulation Compliance Council Exposes Disturbing AMC Violations

by AppraisersBlogs time to read: 2 min
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