Appraisal Fees ARE Being Manipulated
Gas prices in California were $4.25 to $4.50 when oil was last at $100 a barrel. A week ago they were $50+/- a barrel and our pump prices were still over $4.00 a gallon. We are told ‘environmental’ mandated blended methanol is the cause of the $1.30 higher pricing than anywhere else in the Continental US. When those environmental laws were being passed we were told they’d only add from $0.05 to MAX of $0.15 per gallon-NOT $1.30 or 43% more! We KNOW that California politicians have also very recently heavily increased gas taxes in their never ending war against internal combustion. I’ve spoken with friends in the petroleum industry. They readily concede that price manipulation, price fixing and gouging IS taking place, and it happens because refiners know no one will do anything about it. Why? Because politicians blame THEIR tax increases on greedy oil companies! Both sides working together to confuse (& cheat) consumers.
Today, oil dropped nearly 20% to about $43 a barrel. My gas pump price is still over $4.00 a gallon. How odd! Supply and demand economics for oil products have simply evaporated in my state due to political and special interest manipulation.
Fees ARE being manipulated
The SAME applies to appraisal in America. Fees ARE being manipulated. The largest AMCs are also members of REVAA which is an AMC Industry Political Action Group. They reportedly charge annual membership fees of $75,000 for their largest voting board members; and monthly dues of $1,000 a month for other AMCs that want to be members too. The high fees keep the riffraff (small AMCs) out of the club.
Yesterday, I received an article from WorkingRE, a publication of my E&O insurance provider reporting on the activities of Coester (a large East Coast AMC) and Virginia’s AMC regulatory Board. Every appraiser in the country should read this article.
Recently Coester, a REVAA association member filed suit against the Virginia State Appraisers Board for refusing to approve their AMC license. They allege restraint of trade and a host of other far fetched claims. One is that the VA AMC / Appraiser approval ten member board has 6 appraiser-interest members and only one AMC member (who is also an appraiser) plus the other 3 members. My question would be why there are ANY AMC members on a State board regulating appraisers and companies that control them? Coester and its owner have allegedly had numerous violations of multiple states appraisal rules, regulations, laws and Dodd Frank up and down the southeaster US. These have included operating without valid licenses in states; non disclosure of disciplinary actions by principals of the company and a host of other CONSENT acknowledged violations that should prevent ANYONE from doing business in our industry at all.
Instead of restricting themselves to states where they hold a valid AMC license, they sued and the Virginia State Attorney General is urging the Virginia Board to agree to an extension that would permit this unlicensed company to continue doing AMC work in the state until at least December, 2015. Why is unknown. Clearly the Board took the right steps to begin with. The State AG should be backing them up in their decision-not acting as a de facto agent for Coester.
I think the Virginia Coalition of Appraisers has done an outstanding job of getting minimally fair treatment of appraisers legislation passed in their state. Several other state’s appraiser groups have done the same thing.
But how many of these state coalitions can afford to take on the REVAA and its war chest? REVAA has made it abundantly clear that they intend to sue individual states AND state coalitions wherever they have to. They will not willingly give up THEIR Large AMC Only monopolies.
More than ever, we all need to come together in a single national appraisal group to oppose this specific trade group, as well as other national scope issues that arise. We should not expect Professional’s State Coalitions to be replaced, but rather to be augmented by their members and others also being members in the only large, unrestricted appraiser protection membership organization in the country today.
I am talking about the American Guild of Appraisers. The AGA is a Guild within the Office and Professional Employees International Union (OPEIU) of the AFL-CIO. Americas oldest union.
Contact Jan Bellas at www.appraisersguild.org. Or call 1 (800) 660-1835. We don’t charge anything close to $1,000 a month! Right now, first year membership is only $225 and can be paid in quarterly installments. Normal annual membership is only $375; a LOT less than the oppositions $12,000 a year dues.
If, after reading WorkingRE’s article about this issue you still don’t think you need to join with anyone outside your own peer association, just ask yourself this: “Why didn’t THEY warn me that this is going on?”.
Because they have other more isolated self-interest issues on their radar. They are not focused on ALL of OUR rights as licensed & certified professional appraisers.
The AGA of OPEIU AFL-CIO IS focused.
Postscript
Fellow Appraisers,
I have been asked to “remove” comments concerning REVAA from the above post. I’m not sure how one goes about “removing” anything once posted, even if the desire to do so is/was there. I am an appraiser. IF I make a mistake, my training is that explanatory correction is provided, rather than some form of cover up as if the mistake had never taken place. That’s why we used to see addendums rather than retyped “corrected” pages inserted into reports after completion. I am providing copies of recent emails to and from me concerning my original Coester and REVAA posts; and I will be sending Mr. Schiffman a link to the corrected post. Please read BOTH Mr. Schiffman’s explanatory comments as well as the original quoted WorkingRE comments by Mr. Isaac. This does appear to be or to have been an interrelationship among some of the parties involved. Additionally please note that REVAA clarifies (refutes), and states that “…it is not involved in any legal action of its own.” I will be sending a copy of this post to Mr. Schiffman at Mark Schiffman <mark.schiffman@revaa.org>
[Ford email response to REVAA 08/14/15]
Hello Mr. Schiffman:
Thank you for your recent email. I always strive for accuracy in anything I post and if there is an error in the recent blog post in which REVAA was recently mentioned, I am perhaps among the first wanting to insure that it is corrected, second only to yourselves. Certainly neither I, nor any organization I am affiliated with would want to ever harm another organization or company’s reputation unjustly.
I am attempting to post a copy of your email corrections on the site where the original post took place; & the link to the article I was citing from and the paragraph that lead to the confusion over the relationships of Coester; REVAA and NHVA’s interrelated relationship.
Is it primarily the reference that Coester is/was a member of REVAA that you believe could cause harm to your reputation, or other aspects of the article? Your email referenced only the ‘one correction’ which you yourselves have clarified and which I will endeavor to have posted as requested. If there are others areas of concern please do not hesitate to let me know.
I also agree that win-win solutions are always the best and reflect my own personal goals as well as the organizations that I am a member of; otherwise, I would not be a member there.
Best,
Mike Ford
California General Certified Real Estate Appraiser,
SCREA, AGA, GAA, RAA, Realtor®
Received via email 08/12/2015
“Good afternoon Mr. Ford, I hope you are well.
One correction for your article below – Mr. Coester is not a member of REVAA and never has been. REVAA is absolutely not involved in any way with his lawsuit in Virginia or any other state. Nor is REVAA involved any legal action of its own. Further, we don’t intend to in the foreseeable future. The organization involved with Mr. Coester is the National Home Valuation Alliance, which is led by Don Kelly and Jim Brodsky (Weiner, Kider, Brodsky). Both of these gentlemen have past affiliation with REVAA but not in this manner.
Please remove REVAA from your post below as soon as possible – it is not accurate and damaging to our reputation. We are a trade organization representing AMC related issues and work very closely with the appraisal organizations such as Appraisal Institute, National Appraisal Congress. We are members of AARO – the trade association for appraisal regulatory officers and the National Association of Appraisers. We work hard to build positive relationships between regulators, AMCs and appraisers. Furthermore, in regard to membership dues, we have two levels – one at $75,000 as reported but we also have a level at $15,000 to encourage broader involvement from smaller AMCs.
We believe our efforts are best served working together, with appraisers and policymakers, to create a fair and balanced regulatory system.
I am happy to talk further.
Thank you,
Mark”
Mark A. Schiffman
Executive Director
Real Estate Valuation Advocacy Association (REVAA)
www.revaa.org
(612) 716-1812
[Mike Ford] The entire original post that generated my posts can be found at the following link:
Facing License Denial, Coester Sues Virginia Board
The referenced section that lead to comments concerning REVAA is quoted below.
“Who is Behind the Lawsuit
The law firm representing Coester in this case is Weiner, Brodsky, Sidman, Kider PC (Brodsky firm). This is the same law firm used by the veteran AMC advocacy group the Real Estate Valuation Advocacy Alliance (REVAA), in past legal filings throughout several states, and the one also picked to represent a new AMC coalition, the National Home Valuation Alliance (NHVA). NHVA appears to be led by former REVAA Executive Director Don Kelly.
In a possible sign of things to come, the very first goal and agenda item NHVA lists on its website is, “to leverage collective resources to affect helpful (rather than harmful) change through multiple targeted initiatives, including litigation.”
Information on NHVA’s website echoes certain of Coester’s arguments, including the concern that state appraisal boards are violating antitrust laws. NHVA’s stated goal is to “vigorously represent the interests of its Members in the home valuation arena before the federal government and state agencies.”
In the PowerPoint presentation from NHVA’s Initial Meeting, found on the group’s website, one slide lists “Key Issues/Opportunities” for the organization, which include:
Note that four of the seven items seem to relate to fees, suggesting that the NHVA is deeply concerned about appraiser fees.
- State Appraiser Fees Survey Policies and Requirements
- Customary and Reasonable Appraiser Fee Requirements
- Timely Payment of Appraiser Fee Requirements
- State Appraisal Board Antitrust Concerns
- AMC Representation on State Boards
- Required AMC Minimum Quality Control Requirements
- Appraisal Subcommittee AMC Fee Structures
Note that four of the seven items seem to relate to fees, suggesting that the NHVA is deeply concerned about appraiser fees. It looks like appraisers will have a fight on their hands going forward.
NHVA is representing itself as the advocacy organization for smaller to mid-size AMCs. REVAA charges $75,000 annually for membership and representation. NHVA dues are a more modest $995 a month. NHVA’s stated goal is 30 charter members and says that it sees the over 350 AMCs operating nationwide as potential prospects.”
[Ford 08/14/15]
Readers are directed to REVAAs clarification comments and should draw their own conclusions based on factual data presented.
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Great observations Mike. I suspect that the American Oil Cartel and REVAA are represented by the same law firm: Dewey, Cheatem, & Howe
https://www.youtube.com/watch?v=srw3RdiIlrQ
Mike I agree with you about the price of gas. The rest of your article seems to confuse me a bit. What difference does it make what REVAA does? What difference would it make if REVAA has the Attorneys General in all 50 states on their payroll, unless those folks can do an appraisal it will not help them much! We, the appraisers are the only ones that can put a stop to this. I am unaware of any issue where appraisers joined together to accomplish anything. Maybe one of all these appraisal organizations that collect dues and sell classes will actually attempt to do something.
I DO NOT work for management companies and I do not ever plan to work with a management company. I have also stopped working with FHA. I completely understand that many appraisers think that there will just be more FHA and AMC work for them! I can’t wait to see how that works out for them!
Wayne, VaCAP has caused several legislative protections to be passed in Virginia; Louisiana Coalition got some favorable C&R legislation passed. CaCAP (CCAP) with AGA stopped a State Bill from going further (at least temporarily) that would have allowed the AI to get special legislation through allowing THEIR standards to be used as well as any others approved by the head of DRE/BREA (like contingent fees). Arizona has a number of issues they deal with.
My understanding is that VaCAP is also trying to get the State of Virginia Appraisers Board and State AG to enforce Virginia Law with respect to Coester VMS (an AMC). Can’t go into it more right now, but hearsay is they are meeting to consider options tomorrow.
So Wayne, people who are collecting dues ARE doing things. If it matters; my Guild President is an unpaid volunteer. So am I. So are ALL of our State Chapter Leaders. Our parent Unions (OPEIU & AFL-CIO) have waived their normal share of dues for this entire year to help us with our membership drive.
Dues cover overhead. It is MEMBERS that we need even more. We need MORE bodies! To do the kinds of things that I’m doing; and that are going on in Virginia tomorrow; or New Jersey next week. We could use YOUR help too.
email: janbellas@appraisersguild.org
My fellow bloggers and “BT”, please copy and repost on any or all articles where you have seen me post about REVAA. Thank you! REVAA has asked for a correction and if neither Coester (the AMC) nor Mr. Coester, the appraiser / owner are members of REVAA, I would not want to erroneously convey the impression that they are. Additionally please note any other clarifications in Mr. Schiffman’s email to me.Thank you.
[Ford email response to REVAA 08/14/15]
Hello Mr. Schiffman:
Thank you for your recent email. I always strive for accuracy in anything I post and if there is an error in the recent blog post in which REVAA was recently mentioned, I am perhaps among the first wanting to insure that it is corrected, second only to yourselves. Certainly neither I, nor any organization I am affiliated with would want to ever harm another organization or company’s reputation unjustly.
I am attempting to post a copy of your email corrections on the site where the original post took place; the link to the article I was citing from and the paragraph that lead to the confusion over the relationships of Coester; REVAA and NHVA’s interrelated relationship.
Is it primarily the reference that Coester is/was a member of REVAA that you believe could cause harm to your reputation, or other aspects of the article? Your email referenced only the ‘one correction’ which you yourselves have clarified and which I will endeavor to have posted as requested. If there are others areas of concern please do not hesitate to let me know.
I also agree that win-win solutions are always the best and reflect my own personal goals as well as the organizations that I am a member of; otherwise, I would not be a member there.
Best,
Mike Ford
California General Certified Real Estate Appraiser,
SCREA, AGA, GAA, RAA, Realtor®
Received via email 08/12/2015
“Good afternoon Mr. Ford, I hope you are well.
One correction for your article below – Mr. Coester is not a member of REVAA and never has been. REVAA is absolutely not involved in any way with his lawsuit in Virginia or any other state. Nor is REVAA involved any legal action of its own. Further, we don’t intend to in the foreseeable future. The organization involved with Mr. Coester is the National Home Valuation Alliance, which is led by Don Kelly and Jim Brodsky (Weiner, Kider, Brodsky). Both of these gentlemen have past affiliation with REVAA but not in this manner.
Please remove REVAA from your post below as soon as possible – it is not accurate and damaging to our reputation. We are a trade organization representing AMC related issues and work very closely with the appraisal organizations such as Appraisal Institute, National Appraisal Congress. We are members of AARO – the trade association for appraisal regulatory officers and the National Association of Appraisers. We work hard to build positive relationships between regulators, AMCs and appraisers. Furthermore, in regard to membership dues, we have two levels – one at $75,000 as reported but we also have a level at $15,000 to encourage broader involvement from smaller AMCs.
We believe our efforts are best served working together, with appraisers and policymakers, to create a fair and balanced regulatory system.
I am happy to talk further.
Thank you,
Mark”
Mark A. Schiffman
Executive Director
Real Estate Valuation Advocacy Association (REVAA)
http://www.revaa.org
(612) 716-1812
[Mike Ford] The entire original post that generated my posts can be found at the following link:
Facing License Denial, Coester Sues Virginia Board
The referenced section that lead to comments concerning REVAA is quoted below.
“Who is Behind the Lawsuit
The law firm representing Coester in this case is Weiner, Brodsky, Sidman, Kider PC (Brodsky firm). This is the same law firm used by the veteran AMC advocacy group the Real Estate Valuation Advocacy Alliance (REVAA), in past legal filings throughout several states, and the one also picked to represent a new AMC coalition, the National Home Valuation Alliance (NHVA). NHVA appears to be led by former REVAA Executive Director Don Kelly.
In a possible sign of things to come, the very first goal and agenda item NHVA lists on its website is, “to leverage collective resources to affect helpful (rather than harmful) change through multiple targeted initiatives, including litigation.”
Information on NHVA’s website echoes certain of Coester’s arguments, including the concern that state appraisal boards are violating antitrust laws. NHVA’s stated goal is to “vigorously represent the interests of its Members in the home valuation arena before the federal government and state agencies.”
In the PowerPoint presentation from NHVA’s Initial Meeting, found on the group’s website, one slide lists “Key Issues/Opportunities” for the organization, which include:
1. State Appraiser Fee Survey Policies and Requirements
2. Customary and Reasonable Appraiser Fee Requirements
3. Timely Payment of Appraiser Fee Requirements
4. State Appraisal Board Antitrust Concerns
5. AMC Representation on State Boards
6. Required AMC Minimum Quality Control Requirements
7. Appraisal Subcommittee AMC Fee Structures
Note that four of the seven items seem to relate to fees, suggesting that the NHVA is deeply concerned about appraiser fees. It looks like appraisers will have a fight on their hands going forward.
NHVA is representing itself as the advocacy organization for smaller to mid-size AMCs. REVAA charges $75,000 annually for membership and representation. NHVA dues are a more modest $995 a month. NHVA’s stated goal is 30 charter members and says that it sees the over 350 AMCs operating nationwide as potential prospects.”
[Ford 08/14/15]
Readers are directed to REVAAs clarification comments and should draw their own conclusions based on factual data presented.
Fellow Appraisers; I have been asked to “remove” comments concerning REVAA from the above post. I’m not sure how one goes about “removing” anything once posted, even if the desire to do so is/was there. I am an appraiser. IF I make a mistake, my training is that explanatory correction is provided, rather than some form of cover up as if the mistake had never taken place. That’s why we used to see addendums rather than retyped “corrected” pages inserted into reports after completion. I am providing copies of recent emails to and from me concerning my original Coester and REVAA posts; and I will be sending Mr. Schiffman a link to the corrected post. Please read BOTH Mr. Schiffman’s explanatory comments as well as the original quoted WorkingRE comments by Mr. Isaac. This does appear to be or to have been an interrelationship among some of the parties involved. Additionally please note that REVAA clarifies (refutes), and states that “…it is not involved in any legal action of its own.” I will be sending a copy of this post to Mr. Schiffman at Mark Schiffman <mark.schiffman@revaa.org>
[Ford email response to REVAA 08/14/15]
Hello Mr. Schiffman:
Thank you for your recent email. I always strive for accuracy in anything I post and if there is an error in the recent blog post in which REVAA was recently mentioned, I am perhaps among the first wanting to insure that it is corrected, second only to yourselves. Certainly neither I, nor any organization I am affiliated with would want to ever harm another organization or company’s reputation unjustly.
I am attempting to post a copy of your email corrections on the site where the original post took place; & the link to the article I was citing from and the paragraph that lead to the confusion over the relationships of Coester; REVAA and NHVA’s interrelated relationship.
Is it primarily the reference that Coester is/was a member of REVAA that you believe could cause harm to your reputation, or other aspects of the article? Your email referenced only the ‘one correction’ which you yourselves have clarified and which I will endeavor to have posted as requested. If there are others areas of concern please do not hesitate to let me know.
I also agree that win-win solutions are always the best and reflect my own personal goals as well as the organizations that I am a member of; otherwise, I would not be a member there.
Best,
Mike Ford
California General Certified Real Estate Appraiser,
SCREA, AGA, GAA, RAA, Realtor®
Received via email 08/12/2015
“Good afternoon Mr. Ford, I hope you are well.
One correction for your article below – Mr. Coester is not a member of REVAA and never has been. REVAA is absolutely not involved in any way with his lawsuit in Virginia or any other state. Nor is REVAA involved any legal action of its own. Further, we don’t intend to in the foreseeable future. The organization involved with Mr. Coester is the National Home Valuation Alliance, which is led by Don Kelly and Jim Brodsky (Weiner, Kider, Brodsky). Both of these gentlemen have past affiliation with REVAA but not in this manner.
Please remove REVAA from your post below as soon as possible – it is not accurate and damaging to our reputation. We are a trade organization representing AMC related issues and work very closely with the appraisal organizations such as Appraisal Institute, National Appraisal Congress. We are members of AARO – the trade association for appraisal regulatory officers and the National Association of Appraisers. We work hard to build positive relationships between regulators, AMCs and appraisers. Furthermore, in regard to membership dues, we have two levels – one at $75,000 as reported but we also have a level at $15,000 to encourage broader involvement from smaller AMCs.
We believe our efforts are best served working together, with appraisers and policymakers, to create a fair and balanced regulatory system.
I am happy to talk further.
Thank you,
Mark”
Mark A. Schiffman
Executive Director
Real Estate Valuation Advocacy Association (REVAA)
http://www.revaa.org
(612) 716-1812
[Mike Ford] The entire original post that generated my posts can be found at the following link:
Facing License Denial, Coester Sues Virginia Board/
The referenced section that lead to comments concerning REVAA is quoted below.
“Who is Behind the Lawsuit
The law firm representing Coester in this case is Weiner, Brodsky, Sidman, Kider PC (Brodsky firm). This is the same law firm used by the veteran AMC advocacy group the Real Estate Valuation Advocacy Alliance (REVAA), in past legal filings throughout several states, and the one also picked to represent a new AMC coalition, the National Home Valuation Alliance (NHVA). NHVA appears to be led by former REVAA Executive Director Don Kelly.
In a possible sign of things to come, the very first goal and agenda item NHVA lists on its website is, “to leverage collective resources to affect helpful (rather than harmful) change through multiple targeted initiatives, including litigation.”
Information on NHVA’s website echoes certain of Coester’s arguments, including the concern that state appraisal boards are violating antitrust laws. NHVA’s stated goal is to “vigorously represent the interests of its Members in the home valuation arena before the federal government and state agencies.”
In the PowerPoint presentation from NHVA’s Initial Meeting, found on the group’s website, one slide lists “Key Issues/Opportunities” for the organization, which include:
1. State Appraiser Fee Survey Policies and Requirements
2. Customary and Reasonable Appraiser Fee Requirements
3. Timely Payment of Appraiser Fee Requirements
4. State Appraisal Board Antitrust Concerns
5. AMC Representation on State Boards
6. Required AMC Minimum Quality Control Requirements
7. Appraisal Subcommittee AMC Fee Structures
Note that four of the seven items seem to relate to fees, suggesting that the NHVA is deeply concerned about appraiser fees. It looks like appraisers will have a fight on their hands going forward.
NHVA is representing itself as the advocacy organization for smaller to mid-size AMCs. REVAA charges $75,000 annually for membership and representation. NHVA dues are a more modest $995 a month. NHVA’s stated goal is 30 charter members and says that it sees the over 350 AMCs operating nationwide as potential prospects.”
[Ford 08/14/15]
Readers are directed to REVAAs clarification comments and should draw their own conclusions based on factual data presented.
They must have threatened to send your family concrete slippers and send you all on a one way cruise or was it as simple as boiling them in hot oil? Inquiring minds are dying to know.
We know who the parasites are as well as the thugs in the real estate industry. REVAA only confirmed the part they play in the post 2009 extortion scam.
Hi RA, No. What DID happen is the REVAA Executive Director sent me the email I included in the above post. I rechecked my information and he was right. My source article DID say NHVA rather than REVAA re lawsuits. Clarification seemed appropriate to me.
He and I have since corresponded “less coldly” and while we are both open to talking about specific issues, his (legitimate) concern is that those conversations or at least topics would find their way here to this blog. He’s right, so I referred him to our Guild President if there are areas or issues that we may agree on; or areas of shared concerns.
Having said that, my cautionary warning to appraisers remains. With an AMC advocacy group such as REVAA that has the kind of financial backing noted in my posts and Mr. Schiffman’s corrected email; AND the existence of a separate attorney-operated NHVA group that HAS indicated a willingness to sue States and perhaps coalitions; does anyone think individual appraisal coalitions can stand up to them, or oppose their lobbying efforts?
Their primary interests and the interests of appraisers are NOT THE SAME. We ARE going to be on opposite sides on some issues. Where we are NOT on the same sides of an issue it is going to take an organization like AGA or OPEIU and AFL-CIO to ‘negotiate’ or where necessary, to oppose them. These are only TWO of the AMC trade or advocacy groups out there. MANY more exist.
AMCs are not going to go away. Banks eliminated their appraisal personnel overhead by AMC use. They ALSO have at least superficial deniability to any wrong doing by AMCs; and can claim to THEIR regulators that they believe all appraisals are being prepared in accordance with USPAP and applicable GSE requirements. Like it or not, they are here to stay. Its up to us to decide HOW we will coexist in this new environment.
What MAY happen is that smaller appraiser owned boutique AMCs that treat appraisers better, may be pushed out. They make convenient scape goats for some of the offenses that are, or have been commonplace among giant AMCs.
The BEST we can hope and work for (in my opinion) is codifying what MINIMUM reasonable fees are (Y’all know I prefer the federal civil service model-but there are other options too); a better & much faster payment process (FNMA itself prohibits the old “field collect” option); laws prohibiting piggybacking fees on top of appraisal fees; an end to secret and no recourse blacklisting; requirements that adequate time be allowed in all assignments, and especially once an appraiser defines and assignment to be complex.
We need an end to the common practice where lender ‘A’ (lets just call them Wells Fargo for instance) local account executive does not like a value, so they nit pick a report in order to justify ordering a new appraisal. THEN because they now have a much higher value, they automatically turn in the first appraisal to the state Board! They (lender ‘A’ not necessarily WF) say they are required to! Or perhaps Lender ‘B’ (let’s not call them Landsafe) has a sale for $875,000 and an appraisal effective July 15, for $800,000. The buyer & seller renegotiate the deal for $820,000 on July 20th. NOW lender ‘B’ wants the appraiser to “just change the 1st page of the UAD contract analysis to reflect the new price”. My personal view is that this calls for an escrow amendment-NOT an appraisal modification AFTER the effective date. (My state BREA says it CAN be done with prominently explained disclosures-but that it NOT how the request came in to the appraiser involved).
IF it were all merely proper QC, Id have no problem, but every case I’ve seen so far arises from a purported under valuation (maybe even like appraisals at sale price; where the SP is then raised 10% and now the appraisal doesn’t support it; and appraiser PROPERLY declines to raise it in rebuttals). THAT is wrong! Not only is it prohibited appraiser shopping, but they justify it by handing the original appraisers head to the state! This is a regulatory unintended negative consequence.
If one were to research the AMCs in recent articles (for example; Coester) a web page would be found that indicates clients OWN appraiser panels can be used; and that a single national fee applies. BOTH of these things are problematic to me. Nothing wrong with INCLUDING existing panelists, but using them exclusively would seem to be at odds with why AMCs were needed in the first place. Perhaps the advertising I simply ambiguous in error. Under the new TRID system (More appropriately called the Turd system) that replaces the HUD 1, if Good Faith Estimates are off by 10% or more, then escrow closing needs to be delayed until a new TURD can be produced. IF AMCs are citing $300 fees and I charge $1,500 there is a chance the turd will be off and closing delayed. Much easier to get a cheaper appraiser than a competent one that charges more.
State coalitions are great, but I don’t think they can stand up to deep pockets & high powered lobbyists like a National Union can. Both are needed.
AGA needs YOU now! (sounds like a 1940’s enlistment ad). Contact Jan Bellas at (301) 220-4100 or via email at janbellas@appraisersguild.org
Or, call me at (714) 366 9404.
AMCs have all these lobbyist groups. We need an appraiser based organization which vets AMCs/Banks, background checks their employees, ensures they pay C&R, ect while the AMCs pays the 75k annual membership fee. If the AMC/Bank is not a member of the group or does not maintain the group’s standards, collectively we don’t do business with the AMC/Bank. It’s amazing we provide a federally mandated service yet our industry as a whole gets walked on, daily.
Actually you ARE on to something. One of my hopes is that AGA will one day be able to publish a list of appraiser complaints against specific AMCs as has been seen in these blogs from time to time. Of course to boycott a bad AMC you have to have an organization that is large enough to make it a meaningful boycott. Even then, there will always be an appraiser that is hungry enough or starving enough to take the work. BUT, their ‘quality’ usually shows through too.
here is what i would love to see – HUD-1 forms over the last 10 years for all the AMC’s. anyone want to bet me whether or not the fees they charged the banks/borrowers have remained the same like ours have?
(crickets chirping)
Hello?
yeah, i didnt think so.
It takes a “special” type of appraiser to work with AMCs. While inspecting a property I received a cell phone call from a lender wanting to add me to their panel. I was unable to discuss the matter at that time and requested that she send the information to my email. I received nine pages of application.
The invitation starts out telling me how their AMC is a LEADER in the field (I never heard of them). They strive to assist all appraisers who are looking to maximize their time and quality. Their website allows them to monitor appraiser’s efficiency of scheduling and turn times (Just what I enjoy the most). It is imperative (come on…Imperative?) that all assignments be immediately scheduled, notes updated to the website, blah, blah and much more blah!
This wonderful AMC continues with their standard BS requirements of copies of license/certification, at least 3 years of experience, E&O of 500K. Are you FHA approved, ever had an E&O claim, any discipline by state or professional organization? Provide three professional references with name and contact information (so that they can market to my clients). And do not forget to send two appraisal samples.
They continue for page after page explaining how I must accept this and accept that. How I must quickly do all of these things and a whole lot more. I must provide them with bank account info so that they may direct deposit my fee (which they did not inquire about) and then they tell me their payment schedule (what if I am not happy with their payment schedule).
Appraisers MUST communicate with AMC only. Non-compliance with this guideline could result in removal for the appraiser’s panel (everything comes with a threat). Do not include the invoice when you upload the appraisal….(we are trying to cheat the borrower and need your assistance in deceiving them). Now the next part explains how I should select the comparable sales (how could I possibly know that without their help). Next they explain what photos I should enclose in the appraisal (thanks, I always wondered about that too). Then they explain basement sketch, current real estate market, appraiser responsibilities, security, appraiser independence and undue influence (these folks are so knowledgeable why do they need us).
The next part is where they explain that I should be polite, professional, and prompt (gee, I never thought about that). I am told that I represent XYZ AMC and the lender and how I should behave (for 35 years as an appraiser I always thought that I was representing my own company. Where are they when I pay the office bills?) Next they tell me how to dress and what is not appropriate (they must have looked in my closet). Next I am told to be prompt for the inspection, to identify myself with the proper type of identification and deliver the completed report on time. Next they tell me what not to say. This crap goes on page after page. These idiots called me, I DID NOT call them! What makes them think I am willing to extend credit to them? Where is the financial information I need in order to make that decision? YEP it takes a “special” appraiser to work with AMCs.
Appraiser Shortage? How could that be? Why would someone not want to go thru four years of college, work as an appraiser trainee for several years for chump change to earn an appraisal certification? As a licensed/certified appraiser you ONLY have to have three more years of experience in order to work for a scum client such as this AMC! FHA is the newest group to exploit the appraisal industry. Fannie continues to do the CU stomp of appraisers. Wow, what a business this is!
Best post on the whole site, in my humble opinion!
WE HAVE AN ASSIGNMENT FOR YOU! Gee, thank you mucho! What is wrong with folks that just send you an appraisal order and expect you to be sitting there waiting for the crumb of bread? RELO company that sends us maybe two assignments each year ordered appraisal thru our website. There was no “hey, how you doing, whats happening dude?, etc)(THANK YOU) your request that the appraisal be uploaded within Five days is not likely to happen. I have a couple of assignments that are five days past due that were quoted a month ago!This is a result of less and less appraisers. Each day the number of appraisers drop. Personally, I do not have a problem with that. When you take an area that is growing and housing sales increasing…add that to a reduction in appraisers…GEE! Tell me again why an appraiser should grovel at the feet of an AMC? I spoke with an old friend who is the branch manager of our regional banks. She said that of the panel on their rotation one appraiser had stopped accepting any new work and two refused to give a due date (get it when it is complete). This group really needs a “coach” teaching us how we should consider increasing our fees to $365. How stupid is that?Those who want to feed the management companies and other parasites in this business I can only wish you well!
I’ve just found out from a VaCAP board member that if an appraiser wants to challenge an AMC C&R fee with the Virginia board, then an appraiser must accept the low fee assignment, complete the assignment and then file a C&R fee complaint with the board against the AMC.
So VREAB is forcing appraisers in Virginia to accept the low-ball AMC fees before they can file a complaint. Am I the only one having problem with this? I wonder if any other appraisal boards have similar requirements.
Desiree,
Seems odd doesn’t it? But the basis of our judicial and legal system is that one often must suffer a loss of some kind in order to have standing. I don’t like it. Its like saying we can’t report bank robberies unless we had money in that specific bank and can prove that it was OUR money that was stolen.
Im meeting by phone in fifteen minutes, with an attorney whose firm was involved in that B of A / Landsafe class action lawsuit. Our topic is whether or not a class action lawsuit against some; all, or the worst AMCs may be feasible.
I REALLY need people willing to sign on to such a lawsuit to contact the AGA, and to join ! Contact Jan at janbellas@appraisersguild.org. Ultimately the number of people that will sign on is a factor on whether law firms accept cases like these.
I think we should have THOUSANDS of appraisers that are interested. How many are willing to take the next step?…and no, the guild is NOT going to represent those that are not members!
Mike,
I understand what you are saying but shouldn’t an AMC appraisal request with a stated fee be enough proof? I’m just glad I don’t do AMC work.
Thanks to you and your comments, I finally joined AGA and hope others will to…specially those doing AMC work.
Maybe you should author an article on this blog regarding a possible class action lawsuit against the worst AMCs.
Desiree, funny you should mention possible class action lawsuit. More on that later.
I am so happy to be able to welcome you as a new AGA member! (And to say many thanks for you and your own associates work).
Morally I think offering a low fee is wrong. The pretense that AMCs are just allowing the free market system to work Is over worked. They KNOW what truly ‘reasonable’ fees are and deliberately choose to circumvent them.
But legally, I think a lot of states “special interests” intentionally put as many hurdles in the way of enforcement as they could. Personally I want too see steps taken that establish a national MINIMUM for non complex FNMA in conforming loan limits. Maybe something between what I’ve heard VA is ($500?) to $650 that I think they need to be at. Obviously more complicated work or jobs having to be rushed, could and should be more.
Even though our circumstances are different than those involved in the B of A / LandSafe settlement are different, I was still encouraged by it. I have absolutely NOTHING against B of A. MY original mentors were former B of A District Appraisal Managers and VPs back in ’86. I think B of A were unwitting victims arising from their being pressured to buy Countrywide originally.
Conversely, one could also argue their corporate inertia allowed too much time to pass between problems being identified, and not being resolved before the lawsuit became necessary.
Desiree (& others), I had about an hour and a half phone call with an attorney this afternoon to discuss the feasibility of a class action suit or multiple class action suits (each states laws are a little different); or to find out if action in federal courts is indicated. As appraisers we have so MANY appraisal concerns and abuses it may well take multiple suits. I am very encouraged after the call, but follow ups are scheduled. Should know a bit more in a week.
It may also take a successful class action lawsuit of two to get all encompassing, meaningful appraisal reform legislation passed that solves ALL our problems. Why should we aim for anything less.
To the 44 people that sent me messages through the linkedIn system, I keep getting an “error with your email response when I try to reply to each of you in the LinkedIn system. Your inquiries ARE important to me”.
(1) For those that asked the same question; “How do I join”, just contact Jan Bellas at American Guild of Appraisers ( janbellas@appraisersguild.org ) or call her at 301 220 4100. FIRST year INTRODUCTORY annual fee is $225. She can arrange quarterly billing. Normal annual fee is $375. She can accept credit or debit card payments for dues. Aside from the benefits I’ve discussed about fighting for appraisers rights, there are a bunch of other ones she can explain.
(2) For those that asked (seriously), “No. You do NOT have to be a democrat OR a liberal, nor do I expect Anyone to vote DNC slates. Our parent (OPEIU) MAY suggest that at some point, but I’m trying to educate them.
(3) No you do NOT have to be a republican, OR a conservative, nor are we likely to ask anyone to vote GOP slates. (Though as probably the ONLY republican union organizer that will admit to it in the country, I’d like to see us do that just once so that the other sides stop taking union support for granted. Labor CANNOT do well if American BUSINESS is not doing well! I don’t CARE about the multi nationals.
(4) YES! You MAY be either and Independent, Libertarian or Tea party Member and feel equally welcome in AGA.
(5) Appraiser owners of AMCs MAY join as appraisers. You’ll be half right in your views!.
IF you have private appraisal issues that you do not want to discuss on the blog feel free to write me at mike@mfford.com . I answer ALL emails sent to that address.
This is a reply I supplied to an AMC that was questioning a fee quote I made.
“The bid is to cover unknown expectations as to what this rural Subject consists of in terms of home size, age and features, the site size and out buildings, etc. It will also cover the distance to photograph comps and the listing(s) that your clients require.
It appears that you would like us to bid on something that is very rural and we have no idea what it is since there is no listing or prior sale and no public information online. I would suggest that as the AMC maybe it would be wise that for future appraiser requests that information about the home be supplied. This is especially true with the upcoming TRID, the TILA-RESPA Integrated Disclosure rules, problem that we will all have in terms of asking for additional fees for complex assignments that are discovered only after we get there.
This is a very poor business practice on our end, blind bidding. Drive an hour or more one way, find a complex assignment for one reason or another, inform the AMC and then have it cancelled but with a $50 cancellation fee. We are out prior research and travel time, vehicle cost and the loss of income for an assignment.
Our policy is that we have an agreement to appraise a home for a fee. If we inform you and the lender of what is there, since you and the lender have no idea, and the assignment is cancelled, the lender is responsible for a reasonable consultation fee plus expenses since we apprised you of factors that you did not know and of which you were not aware. If you and the lender want to place the responsibility on us to inform you and the lender of the property factors that influence the lender’s financing decision do not expect it to be a trip fee but a significantly greater consultation fee plus expense charge.”
Randall, you are absolutely right! Back in ‘the old days’ even the big boys like B of A routinely compensated for appraisers time related to subsequently cancelled appraisals. Heck, even FNMA did (REOs)! Then the euphemism “trip charge” was coined and a presumption developed that all we were entitled to was token compensation for gas and time. Usually $25! Ocwen used to be one of the worst for this. They always paid it, but the amount was insultingly low compared to time & costs expended.
FINISHED!
Fellow appraisers, please visit http://mfford.com/html/c___r_fees.htm
Apologies for using my personal site but logistical and time constraints made it necessary.
It is to read a draft proposal for minimum national appraiser fees. I appreciate some believe no one other than themselves should set fees, and I concur. Except, in the real world of today where someone (lenders and AMCs) are ALREADY SETTING your fees. If not directly, then through ruinous less than customary OR reasonable fee competition.
Im interested in your meaningful, constructive feedback as well as comment & discussion here.
For those that insist ONLY regional fees are practical, this same system works for the lowest to highest regions of America. Subtract 13% for low cost areas; add up to 9%+- for higher cost areas.
Operating premises were:
1. AMCs are here to stay. Liked or hated, they are part of the chain now.
2. LENDERS want AMCs to offer one size fits all pricing. This MAY come close to doing so baring complex assignments. Even there, an inferred hourly equivalent is suggested.
3. If WE don’t set “reasonable” minimums for ourselves, then others will do it for us (or to us).
4. Framework allows for and includes inducements for trainees or less than certified appraisers-who have been largely excluded or ignored by AMCs in recent years.
In addition to posting here, PLEASE also email comments to JanBellas@appraisersguild.org
We are going to start reaching out to state coalitions and other appraiser peers groups. We hope to incorporate helpful comments or views in that effort. In the meantime our parent union is already being contacted to see how we can best proceed.
Thank you for taking the time to read and respond. Mike Ford, AGA; OPEIU/AFL-CIO
i totally agree with your fee figures Mike, and i think they are much more inline with what an appraiser fees should be. however, i still dont understand how a 1099 self-employed appraiser, can be told by anyone what their fees should be. if an appraisers fees are controlled by anyone outside of their control, they are no longer in business for themselves and they are now an employee.
anyone who has a GS# is a federal employee are they not?
APPRAISERS should be the only ones in control of their expenses/businesses. only an APPRAISER knows what his expenses are. an appraiser is either self-employed or they arent, and i dont think any business owner should be considered self-employed if they dont have full control of their own businesses. right now we are 1099 self-employed business owners with very little control of our businesses/expenses, and its WRONG, and we are losing people every day because of it.
the bleeding continues . . . . .
I agree with your fee projections as well Mike but those same projections are a pipe dream as long as appraiser’s refuse to boycott for fair fees. Which leads me back to my reason for leaving the business so I could earn those same fees elsewhere.
Hi Bubba~RA II; & RA the First
(RA-II) You misunderstand. You do NOT become a GS employee. I am only talking about comparability of compensation, or “parity”. The federal government tells people that they must pay vendors minimum fees or compensation all the time as a condition of doing business with the federal government.
Some kinks remain to be worked out but the probability is to seek to have this (or very similar scale) adopted as a DEFAULT minimum C&R fee in any state that has no stipulated process for independent study of C&R fees. It simply would say IF you have not otherwise ‘proven’ specific fees are C&R, then THESE would be the default scale to be used.
It might also be used to challenge state studies that appear to include or be influenced HVCC/AMC low fees.
RA#1 ya old curmudgeon! Ya done went and got Bubba Jay to be an apprentice retiree! Sincerely hope it works out for him. As for boycott, I don’t think we need it. IF OPEIU was able to get AB 624 spiked in just a few weeks, I think THEIR parent union (AFL-CIO) should be able to get this favorably considered without resorting to traditional union job actions.
Just like those that get laws and regulations quietly passed for their benefit; I think we can get something like this passed for the 80,000+ appraisers that are still left…not to mention the taxpayers who keep getting screwed by shoddy, unprofessional, discounted half-assed appraisal work (like the 1/4 million Countrywide/WAMU appraisals reviewed by FDIC).
Give us a hand! Pass proposal along to appraiser friends and ask them to write Janbellas@appraisersguild.org and go on record as supporting the proposal. Thanks.
SEPARATE ISSUE: Had a chance to speak by phone to blogger Wayne C out of Texas. What a pleasure, and what a true gentleman! I look forward to future communications.
Show me a national boycott of all AMCs and I’m all in Mike both financially and physically.
When I started appraisals averaged 9 pages and we were paid $350. Now mine are running 40-50+ pages and I’m lucky to get $350. There are still only 3-4 pages that anyone is interested in. Except the 18 yr old “senior, supervisor, appraisal review specialist”.
Scumbag Brian Coester trying to justify his bottom of the barrel Coester VMS AMC appraisal fees!
CoesterVMS Files for Patent for Customary and Reasonable Fee Calculator