Concur.

When I started like 15 years ago or so, everyone had to have a fee schedule from panel applicants, it was a standard requirement. The proverbial standard fee came from the internal lender surveys of those fee schedules for all appraisers on panel, and they picked the lowest number that the majority of appraisers on panel would accept. Appraisers higher priced had the choice to compete or not, appraisers lower priced were more likely to be overlooked, not having a good sense of their self worth and likely to not provide as quality of work product as a result. All fees were uniform, easy or tough, and you took the good with the bad and far fewer people gamed the system. There was no ability for appraisers to underprice each other to gain the lions share of work assignments, and cost savings if present were returned to consumers with a direct billing process, cod’s were common.

The inexperience and lack of industry qualification of amc management firms have been apparent since day 1 sometime in 2008. 2019; “If you don’t know what a standard fee is by now, we can not help you.” Back then lenders respected the rules and did not dip into the appraisal fee in any way what so ever. Things ran smoothly, appraiser populace flourished, and earnings were better aligned with commission based interests which provided better independence for appraisers. It’s apparent to me that all the layers of rules are implemented purposefully in a systematic effort to eliminate this important independent layer of checks and balances for appraisers. That and also illustrating the general incompetence and disregard for rules and ethic that nearly every single tech company of all sorts on this planet is steeped in.

Big data, big joke. Sometimes the manual solution is the best solution.

Kind words Baggs, Thanks.

TAF is really what IVPI should have been-or vice-versa. In the end, scoundrels adopt the language of the protectors. Not TAF – I think they failed, but I believe most of the volunteer board members believe in their work and the process. Think more of Congress.

Rarely do they perform a swindle or deception of taxpayers without dressing it up in acceptable language first.

I think we have to either go with full federal regulatory oversight of uspap; OR complete elimination of AMCs. We know AMS would replace them which has even greater potential for chicanery but if coupled with a minimum C&R FEE that MEANS something; a mandatory turn time range of 5 to 10 WORKING days using federal definitions of what a normal working day is, and a mandatory monthly publishing of average fees paid to appraisers by each lender.

Alternatively, dump TRID and the ability of any lender to price fix before the appraiser is consulted on the specific property. Make a payment on or before the appointment, by the borrower mandatory. Lenders have already proved there is far more fee pressure and coercion from withheld payments than there ever was with COD.

Sadly though, TAF has already destroyed the public trust in appraisals and now we are seen as no different than an AVM.

Mike and Marion, both of my appraiser heros. The majority of what I have learned is because of you two and several other less consequential appraisers, arguing the merits, steeped in regulatory accuracy. I never thought of it that way, state by state, thank you for the logical illustration.

For a long time I advocated for the IVPI proposal, linked again for posterity I suppose. Print it while you can it won’t be available online forever. Then I began to market away from amc’s and qualified the client better during the solicitation process, as they say. A true rotational clearinghouse approach would be beneficial for most but actually more dangerous for many whom are reluctant or unwilling to deal with the antics of advocates whom seek to circumvent basic ethic. Ooops, I said it, the far majority of separation actions are illusionary and I do have emails to prove it, somewhere in the 6 legal drawers most likely. You’ll never see them, I alone can not go against multi national billion dollar lenders. Reasons why the VA is not all it’s cracked up to be and why to this day the most effective solicitations are to the lender directly regardless of how they dole out the orders. Inconvenient truths of the appraisal industry.

Actually no link, just search ‘workingre ivpi proposal’, you’ll find it. ALL new appraisers before 2008, a must read document.

My latest solution; Thorough auditing of all amc’s and the actions of their employees nationally. Non licensed people can and should be held personally liable for the damaging actions they have engaged in. Non licensed panel managers and appraisal clerks think it’s an easy foot in the door job. Think again.

Partly correct Marion. It depends on your specific states implementing language for both FIRREA and Dodd Frank. Some states did it the right way and said “Gee this MINIMUM standards thingy sure sounds sensible, lets adopt it for ALL appraisals performed in [insert state here].”

Other states became schizophrenic about it and can’t decide what their laws are anymore.

Depends on the changing tides and winds.

The biggest threat to appraisal integrity today are the Appraisal Management Systems (AMS) like Mercury and any others that allow banks to populate their own appraisal roster.

All the evils of pre-HVCC coercion without any of the paper trails or smoking guns typical of a corrupt or incompetent AMC. Almost impossible to prove appraisal shopping or coercion took place unless the agent is stupid enough to come right out and send the appraiser an email to that effect [yes, it DOES happen that they are that stupid]. Yes, banks are dumb enough to cancel the order at the LO or agents request and reorder from a number hitter.

AGA is just waiting for one such case to fund at the unsupported higher dollar amount before we file a complaint with states and fed on behalf of our member.

But something to consider, really, really, consider, is that, Appraiser Independence is limited to FRTs and regulated banks.

All other lenders – and loan types – the mortgage broker can order.

Soo, as deminimus goes up, there is even less need of AMCs.

Oooooppppsss.

Call your old mortgage broker buddies. Check it out.

.

The only rule that actually matters, is the rules consumers set for themselves when they participate.

1. Debt is dangerous.

2. The larger the debt, the more dangerous it becomes.

3. If predatory lenders are held accountable, it will provide none or wholly inadequate relief to the individually injured homeowners.

4. The regulatory mechanisms in government answer to the will of corporations far ahead of the well being of citizens these days. Nearly all regulatory bodies have fallen victim to regulatory takeover by major corporations.

Rules to live by. Easy to teach.

Did you know there are people whom pay cash for houses? Did you know you can get a rocket mortgage in only 5 minutes time with the press of a few buttons? Did you know lenders offer the ‘trust option’ where you don’t even need a non advocate or an agent and the lender will make it all happen for you with guaranteed results? Fools jump in first.

And will you still own real estate, if you walk away? And will the GSEs dictate the value of your real estate, without any path for you to disagree with what they tell you? Are their databases filled with “inspection” data from people who may or may not be loosely trained by an AMC to take pictures? And they are going to limit what a buyer for your property can pay, if a mortgage is required?

So, if I have this correct, the law that protects consumers with appraisals is within the Truth in Lending Act, (Title 12) but the appraisal section of the truth in lending act is only the law when agencies determine the law is appropriate? And there won’t be any public meeting about when the agencies decide if the law is appropriate?

Funny because I did not find anything in the constitution that says that agencies get to decide if laws are applicable or not, and then write their own rules to replace laws, when they determined the law wasn’t applicable.

Does the AFL-CIO have constitutional lawyers hanging about?

Fortunately, you are not in charge of anyone elses credibility. It is the message and the substance behind the messages that allows people to make up their own mind.

Dang ain’t you special

Now I’m getting it? The Banks control the process full on now, it was bad before, but now the Feds and the banks are blatant about their grifting. Thanks to the “swamp drainer” Maybe if you Baggins step away from the mirror and read what other people say you might have an opinion that could be taken seriously

How much dignity would any of us have without private property rights? I don’t feel like I’m in an appraisers prison, this job afforded me more liberty and success than anything else I had tried before.

Thank you Mr Ford. I felt that perhaps an appropriate action would be to yet again highlight how the fed is the central banking master, despite the illusion of accepting public input. Lenders constantly push the line, feeling where the response and resistance level would be. Over time and related to oftentimes coincidental political environments, blame can be redirected and very influential policy follows. Fed policy most certainly does not come down to whom one voted for in a single electoral cycle. I find your articles and contributions to be highly educational and do make efforts to read through the details. There are a long line of appraisers whom push the self interested response mode and agenda, dime a dozen. Ethical appraisers should care about the bigger picture and the opportunity a sound lending system represents for individuals. We judge them by their fruits. Each appraiser must ask themselves if they’re willing to help future generations to be fleeced by lenders, or if they will resist. They either take hybrids or they don’t. They take the time to read all of this, or they don’t. They are virtual advocates for big banks or they are not.

I am honestly very surprised this many appraisers came together over this issue. They used their time and hands for more important efforts than just waving fingers around.

For years I keep hearing over and over again “Why doesn’t somebody DO something?”

Then when we try to show appraisers that people ARE trying to do something AND that appraisers have made far more impact than anyone suspected, y’all miss the point completely.

OK, faults all mine. I failed to point out what I thought was the obvious significance of the content in this article. My apologies.

Clearly, Retired Appraiser is correct and we should all turn in our licenses tomorrow and seek the high paying uber jobs that are so plentiful while waving a fond single digit farewell.

The “FEDs’ who are controlled by the bank lobbyists (The SWAMP) you mean

Now you’re getting it. The banks. Not to be confused with the politicians whom either by choice or by force, must answer to them.

Dang! I just right now finished answering the last poor soul whom was completely ignorant regarding what’s going on with this issue, and whom should be being blamed about this. Linked below. Don’t be a useful idiot, save the pot shots for the peanut gallery. Step aside for people whom actually know what they’re talking about.

http://appraisersblogs.com/feds-deny-public-hearing-re-appraisal-threshold