Transparency… Where is it?
Is transparency with the lender?
Did the lender explain to the borrower the fee they (the borrower) are paying to the AMC and the benefit they are receiving? Oh wait, what benefit is the AMC to the borrower? Was this fee disclosed verbally, in writing or anywhere? Did the lender disclose any relationship they have with the AMC?
Is transparency with the AMC? Did the AMC disclose their fee to the borrower? Did the AMC disclose how much the appraiser is being paid? Did the AMC explain any benefit of their service to the borrower? Did the AMC explain how the appraiser was chosen? Did the AMC disclose how they arrived at the C&R fee to the appraiser?
Is transparency with the appraiser? Did the appraiser disclose the appraisal was ordered with an AMC? Did the appraiser disclose the compensation received for the appraisal? Did the appraiser disclose any fee required to deliver the report?
Well it appears the appraiser is the only party providing any transparency. If the Dodd-Frank Act and State Regulations were passed to protect the consumer, why is it the appraiser is the only one providing any transparency?
While we are on the subject of transparency, are you, the appraiser, disclosing the request for revisions from the AMC and/or client within your report? If not, you should be! VaCAP recommends copying and pasting the request for revisions within the report and then responding. Why do this? Transparency! Everyone, the AMC, the client, the investor, and the borrower are all informed of any revisions requested. And if you end up defending your work against a complaint filed with the VREAB, they too have been informed! This not only protects you, the appraiser, it protects the consumer.
Sample verbiage would be:
The original appraisal report was signed and delivered on May 1, 2016. On May 5, 2016 the appraiser received the following request: Copy and paste the request here.
Appraisers Response: Type your response here. Make any corrections needed within the report and outline the changes here. Be professional in your response. If you made an error, admit it, correct it, apologize for it. Be sincere.
Make sure to add the verbiage: The appraisal report was signed and delivered on May 7, 2016.
Why is the appraiser is the only one providing any transparency?
- AMC Engagement Letter: Appraisers Do Not Include Your Invoice - July 28, 2023
- We the People… - April 9, 2023
- Federal Valuation Agency Impact on Appraisers & the Public - July 22, 2022