Appraisal Fee Disclosure – Call To Action
Important – Call to Action
This must be done by Tuesday July 7
The Consumer Financial Protection Bureau (CFPB) is requesting comments on the proposed amendment to the “Know Before You Owe” mortgage disclosure rule, which proposes to move the rule’s effective date to October 3, 2015.
We feel it is very important that the appraisal fee be disclosed separately from any add on fees such as an AMC fee.
Recently 23 state appraiser coalitions including the Louisiana Appraisers Coalition worked together and submitted a letter to the CFPB about making it a requirement to separate the fees of the AMC and the appraiser at the closing table on the disclosure.
Now it is our turn to do our part and I am asking that you take a minute to make a personal comment to the CFPB. This is a part of appraisers having a seat at the table in our industry.
Right now there are 79 comments and almost everyone of them are from banks and AMC’s.
We appraisers also need to express our opinion on this issue.
Keep it simple; it’s about transparency for the consumer. There is a sample comment below. Feel free to use it or create your own. It’s just important that you make a comment.
Please click here, then look in the upper right corner of the webpage for “Comment Now!” to submit your comments. Let’s flood them with comments from appraisers.
Once you have done this please forward this to another appraiser.
Sample Comment:
Feel free to copy and paste, edit or submit something totally different but please make a comment.
“Appraisal” fees to consumers continue to rise while the actual payments to appraisers have fallen. As with any business, a focus of third party appraisal management companies is to increase their profits. Under the current disclosure, there is no benefit or accountability to the consumer since the AMC fees are not listed independently.
The result of this lumping together of the fee often misleads the consumer to think that the appraiser fee is high. Currently, (with no separation requirement), a consumer might see an “appraisal” fee for $600 or more, with no awareness that the appraiser they met at their home and has completed their report is only being paid as little as $300 or less.
We ask that the Bureau recognize this major concern and take this proposed delay, in an attempt to “get it right”, as an opportunity to address this issue. I implore that you implement this simple solution of requiring the actual appraisal fee to be disclosed on its own, not an inflated fee that includes other administrative bank or AMC “add-ons”.
By Bill Cobb, Accurate Valuations Group
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its deceptive and a lie to combine the appraisal fee and the AMC together, call it “Appraisal Fee” or whatever, and make it look like the appraiser is getting the entire fee when they are not. the AMC’s and the banks dont want the truth revealed because they dont want anyone to find out that/how the appraisers are getting screwed nowadays.
its so very sad that we ever have to vote on, or make special requests, for things that should easily be considered pure common sense. its even sadder that it took this long to get here.
the bleeding continues . . . . .
Just commented. Looks like a lot of appraisers commented today thanks to this post but not nearly enough. Thanks Appraisersblogs and Bill for the heads up. I’ll share this with others.
Honestly, I am surprised that 323 appraisers still care enough to waste their time signing it. One can only imagine that appraisers are busy with their DIY Embalming Kits (Collateral Undertaker).
Thank you guys for being one of the few to stand up for the rights of this apathetic cesspool of pseudo professionals.
Excellent! 567 comments as of 07/07/15 – 2pm mst.
My comment;Â Distinctly different services, should require distinctly separated fees. Appraisers should not be selected on a basis of whom has the lowest fee, unless such a low fee benefits the consumer in terms of cost savings. Currently with improperly co mingled amc and appraiser billing in a single line on the HUD1 form, cost savings from reduced costs of appraisal services are not returned to the borrowing consumer, but rather are used as a financial incentive to the amc as a reason for that lowest priced appraiser to be the preferred selectee. Variable amc profits based on variable appraiser billing, where cost savings are not returned to the consumer, is a violation of the spirit of disclosure laws regarding service fees being required to be of benefit to the consumer. Without this necessary separation of fees, amc’s nationally have unintentionally been operating as suppressors of open market appraisal fees, to the severe detriment of the appraiser community. Also, rules like C&R customary and reasonable appraisal fee rules, per RegZ have become bureaucratic and unenforceable, because amc’s cannot be audited for compliance. Properly separated fees on disclosure forms could result in the ability of state and federal regulatory bodies to audit amc’s for compliance with C&R rules. Please read this professional letter regarding the dangers of amc’s and these improper and illogical co mingled billing practices, put forth by one of the many state appraisal groups out there.
Thank you.
Baggins
http://appraisersblogs.com/appraisal/amc-dangers/
Am I the only one laughing at the fact that this WHOPPER OF A LIE (fictitious appraisal fee) is blatantly included in a document that is protected by a TRUTH IN LENDING LAW! How freaking insane is that people?
You would think they would at least have the decency to change the name of the law if the primary intent is to spit in the eye of the borrower.
Posted letter numbers continue to climb, although the comment period is now closed. Probably they’re still processing the letters and posting them. Viewed dozens of copy paste comments from this ApprsrBlogs article, and many other unique letters. Current number is 830 letters and climbing, as of the morning after comment period deadline. Interesting reads, with a strongly uniform message; It is unfair and deceptive to lump the amc and appraisal fee together. Many interesting letter reads that were educational and informative. Suggested reading. The appraiser community finally agrees on at least one thing; Appraisers fees should not be combined with amc fees in disclosure forms.
APPRAISAL FEE DISCLOSURE ??? Â Â If that is really what we want I think we are writing to the wrong people. Most of us know what the Appraisal Standards Board is. For those who may not: The Appraisal Standards Board (ASB) of The Appraisal Foundation develops, interprets, and amends the Uniform Standards of Professional Appraisal Practice (USPAP). The first sentence of Preamble of USPAP states “The purpose of the Uniform Standards of Professional Appraisal Practice (USPAP) is to promote and maintain a high level of public trust in appraisal practice by establishing requirements for appraisers.”
It would seem to me that Standard 2 of USPAP could be changed to REQUIRE all licensed and/or certified appraisers to state the payment amount they actually received for the subject appraisal on every page of the report that indicated a property value or contained the signature of the appraiser. If this change to USPAP were made it would not matter what fee an AMC or lender wanted to hide. The appraiser would have no choice but to follow the guidelines required by USPAP and “a high level of public trust in appraisal practice” would be improved. (it could also require that the demanded turn time be stated on those same pages)
If the fee we actually receive is disclosed in every appraisal we prepare it will serve no purpose for the government, banks or AMCs to keep that information secrete in a Truth in Lending Statement or other paperwork.
We are writing to the wrong folks!
i just received an appraisal order form iMortgage Services for a UAD 1004 w/MC for $175. Â i have no idea what they are ultimately charging the borrower as an “appraisal fee”, but i am guessing the total will “look” normal and will be made to look like nothing is going on at all.
this is totally absurd and needs to stop. THIS is why the fees need to be broken out – so everyone can SEE what the heck is really going on.
the bleeding continues . . . . .