If fees were appropriately separated, then amc’s could be audited for C&R compliance. You can bet that some of them will continue to lobby and fight against transparency in billing. If the amc service is worthwhile, valid, and is worth the expense, there should be separated billing. Distinctly different services should require distinctly separated billing disclosures. Same old story; Many an amc will simply call down the list of appraisers until they find the cheapest servicer regardless of quality or depth of the appraisal product, to maximize profits. And with flat rate billing policies, when one appraiser wins on C&R, the next appraiser is forced to lose, in order for the amc to maintain a profitable operation. The reason being is they have agreements with lenders where all orders have a flat compensation rate. Amc’s actually operate as suppressors of free market appraisal fees, in those scenarios. Appraisers who discount more, provide more financial incentive to be the preferred selectee, which is not how a non-advocate appraiser is supposed to operate. Cost savings from lower cost services should be returned to the borrowing consumer, and not pocketed as a financial incentive to select that appraisal servicer. A more appropriate billing structure would be to force each individual appraiser and amc management fee be tied to that individual deal, and to prohibit flat rate billing by amc’s. Don’t take my word for it, but rather read into the issue with this highly detailed and informative explanation page put forward by one of the many appraisal professional groups out there. 

One of the best explanation pages on the amc business structure question I’ve ever read. http://appraisersblogs.com/appraisal/amc-dangers/

You will find it far easier to have the name “Truth In Lending Law” changed to “Zero Truth In Lending Law” than you will obtaining HUD-1 transparency.