Appraisers to Comment on AMC Registry Fees
AMC Registry Fees not be passed on to the appraiser…
The Appraisal Subcommittee is accepting comments on the proposed rulemaking to implement the collection and transmission of AMC registry fees.
VaCAP has submitted a letter in support of the registry of AMCs by the ASC and is strongly advocating in the rulemaking that the registry fees not be passed on to the appraiser or consumer.
We encourage each appraiser to provide comments to the ASC. Comments are closed on July 19, 2016, so please comment NOW.
Post your comment here. Comments must be submitted by 07/19/2016 at 11:59 PM
As of this submission, there were 42 comments submitted. Thank you to all Virginia Appraisers who submitted comments!
Excerpt of VaCAP’s letter:
Most AMCs operate on the premise of “fast and cheap.” The typical practice is for an assignment to be email / text blasted to every appraiser on the AMC’s panel. The first to accept receives the assignment. The consumer is unaware this is happening and in many cases the consumer is unaware an AMC is involved at all. In this scenario, the AMC has not done any research of the subject property, and in most cases, is unfamiliar with the locality in which the property is located. If the “Appraisal Management Company” is to manage the appraisal process, shouldn’t identifying the basic information on the subject property be the first step? The first appraiser accepting the assignment that was blasted to every appraiser may not be experienced nor competent to appraise that property type and thus the consumer is harmed.
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People are not seeing the big picture with this one.
<>From AMCs that have been in existence for more than a year an annual registry fee of $25 multiplied by the number of appraisers working for or contracting with such AMC in such State during the previous year<>
Now what exactly do they need that much money for? What good will this do for appraisers? My crystal ball is glowing, and this will restrict an already restricted market for attaining CR fee appraisal work.
A registration fee scale based on the volume of appraisals sent through the amc or instead based on the number of amc employees or scaling for their total gross revenue would have been a more appropriate solution.
I’m not writing a letter because obviously this is lining up with a future reduction in applicable qualification criteria for appraisers. These companies will have to be assured the appraiser will play ball, or they won’t even send orders in the first place. I see application fees in my future. I see 95% of my client folders in my drawers going instantly from marketing potential to marketing restriction. It’s HVCC all over again, and loss of client and marketing potential is the obvious result. Who in the hell suggested the fee should be calculated per appraiser without any attention to how many panels the appraiser may be approved on? Obviously this comes from the think tank which promotes firm style appraisal and proprietary engagement, rather than that of open market free competition.
If you’re an appraiser who only works with a handful of amc’s, you’re limiting your potential. They play the market and so should we.
the ASC will be talking about 20 years from now.
and nothing will have changed – NATIONALLY.
the circle jerk continues . . .
AMC registry fees are not the issue, they are the symptom. The AMC business model was conceived and designed by and for lenders and lender interests groups to maintain control of the appraisal process and those appraisers that work in the lending appraisal arena. AMC/lenders control the fees, the turn times, the comp selections, comp adjustments, etc, etc. How can the AMC model improve appraisal quality, when the appraisers have minimal input or no influence and are basically shut out of an appraisal process maintained by NON-Appraisers????? This AMC model is being impose at the expense of appraisers income, while deceiving consumers. Until the powers to be are willing to give the appraisers input and control on the lending appraisal process, for the appraisers the AMC business model is basically professional slavery.
After 7 years of signing every conceivable petition and taking the time to write to every member of Congress plus the White House why would I waste my time on signing something new?
I threw my appraisal career in the dumpster along with 2,000 sf of office furniture and computers in 2009 when it’s value became considerably less than used toilet paper.
Answer: I wouldn’t waste my time on signing it. Why? Because NOTHING will change. They are simply paying you lip service by telling you they’ll read it. I will be happy to send them a F U note though.
Allow me to clarify even further. Here is a hypothetical situation to consider:
In the event that this “profession” managed to implode (even further) with a severe shortage of appraisers and a $1,000,000 offer to each appraiser willing to make a 5 year commitment. What would you do?
Personally I would laugh my ass off and throw a “I Told You So” for every member of Congress. I would then mail a polite response to the agency who offered me $1,000,000 stating:
1. You are insane if you think I would return to that Hell On Earth for $1,000,000.
2. I would tell them where they could shove their cach.
Came across this letter by Stephen Linville w/ Alterra Goup => Appraisalbuzz => ValuationExpo => Clearbox => CRN => Joan Trice…while browsing the comment section.
There is absolutely nothing in the letter benefitting appraisers or promoting appraiser independence. It’s just a pro AMC letter! Not a bit surprised…
You have to consider the source!
Did Steve Linville retire? He spoke of moving towards retirement and working with Trice’s ClearBox in the Valuation Expo podcast with Joan Trice (podcast with Appraiser Coach Dustin Harris from July 2016).
Gee…I love it! I really wish that the AMCs would require a fee of about $10,000 to $50,000 for each appraiser. It that is not enough….maybe $500,000 to $1,000,000. Whatever the fee that is needed to make the damn stupid appraiser STOP!…We really do need to get our heads out of our asses! Having fun yet?