Thing of Value
- Hybrid Assignments, the Consequences - February 7, 2019
- Bankers Concerned About Appraisals - October 18, 2017
- Third Party Blues - July 19, 2017
Pay for an assignment?
“Never. It’ll never happen!”
It happens all of the time. While most appraisers would never dream of violating the Management portion of the Ethics Rule by paying for work…many do it every day without giving it any thought.
Management: An appraiser must disclose that he or she paid a fee or commission, or gave a thing of value in connection with the procurement of an assignment.
Comment: The disclosure must appear in the certification and in any transmittal letter in which conclusions are stated; however, disclosure of the amount paid is not required. In groups or organizations engaged in appraisal practice, intra-company payments to employees for business development do not require disclosure.
USPAP doesn’t qualify any dollar amount, does it?
It merely addresses a thing of value. When portals, clients, and AMCs charge you $5, $10 or even less just to process your report…you must report that fact in your certification and in any transmittal letter.
The test on whether you must report this is whether the portal, client, or AMC will permit you to upload your report without paying for the transaction.
If the answer is NO, then it means that you’re giving a thing of value in connection to procuring the assignment.
Failure to disclose this leaves you open to discipline.
That’s the department and the board’s disclosure to you.
Illinois Appraiser Newsletters – Volume 4, Issue 3
So the mercury network fee is something that should be mentioned in a report?
$5 or $10? How about disclosing that they gave up 50% of their entire fee to an AMC in exchange for the order?
Runs contrary to the little concealment clause that most appraisers sign off on with AMCs.
Let’s be realistic here guys. How many of you are honestly going to disclose within your appraisal that paid an AMC $300 of a $500 appraisal fee to get the job?
If you are willing to do that feel free to call 1800 DUMBASK and register today for your free tatoo. We will gladly tatoo DUMBASK across your forehead for no expense.
Being desperate enough do such a thing is one thing. Be fool enough to admit it to the public however is an entirely different matter.
[Unfortunately, well over 50% of the appraisers out there today would qualify for this tatoo.]
I guess I’m going to have to report AppraisalPort fees in my reports from now on. Comment states “In the certification and any transmittal letter”??? But we can’t modify the certification of the 1004 and 1073 and I don’t submit transmittal letter. So where should I disclose it?
And that discipline is nothing more than basic education and a small fine most places. Sad but true. Beyond just a portal fee, improper bundling of appraiser and amc fees means every single discounting appraiser out there charging less than C&R rates is providing a thing of value without properly disclosing it. Everybody knows how to get amc orders; provide an appealing profit margin to the amc by reducing your fee beyond the competition. If that’s not producing a thing of value to attain work orders ahead of the next appraiser, I don’t know what is. How to get amc orders? Provide more appealing profit margins than the next guy, or at least get on board with the constant reduction fee schedules. Improper bundling of fees creates an ethical challenge. The amc and appraiser provide distinctly different services, and the fees should not be bundled or the distribution of fees concealed from consumers, lenders, or appraisers. The amc is an advocate of the client, the appraiser is not. Bundling of fees has imposed unethical advocacy based pressure on appraisers nationwide.