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 . . . . .

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!

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.

My comment; 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/

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.

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 . . . . .