AMCS have ALREADY illegally capped appraiser fees. Let’s go a step further. AMCS in collaboration with Banks have also conspired to fix appraiser fees before the appraiser is ever even contacted for an assignment.

AMCs in collusion with banks, other AMCs and a whole host of related special interests have formed ‘trade groups’ to continue to prevent appraisers from receiving reasonable and customary fees as mandated under Dodd Frank; even conning the FTC to plead their cause. Investigating how THAT complaint ever got processed with only 2 or 5 total commissioners would be interesting all by itself, but that’s another issue.

Dustin, there can be no moral equivalence between two parties when one of those parties has no discernible morals to begin with. You are increasingly losing credibility with every post defending what we all know is a completely corrupt system. Not merely inefficient. Blatantly Dishonest.

For the record, there is no one named Dawn Aubrey listed in the ASC National Appraiser Directory.

Put forth a full article if you have the time please. Not all of us are allowed to participate at the secretive Appraisers Forum. Censorship is running rampant these days…

There isn’t enough space here for that.

That would be the amc’s lobbying to cfpb when selecting the new hud1 disclosure form, and the continued absence of an individual amc line item in today’s disclosures. The other hud1 proposed closing form did have an individual line for amc fee disclosure, apart from the appraisers fee. The amc companies would not be able to drive down appraisers fees for variable unearned additional profit if they were properly recognized as a stand alone service and the lender and/or consumer had to write two checks, one to the amc and the other to the appraiser. They drive the appraisers fee down in order to drive their own profits up, courtesy of improperly co mingled fees.

Yes, the amc is often a profit center for parent companies. Your solution?

Appraisers shall not provide a financial incentive to be the preferred appraiser selectee. This is against fdic rules on fair appraisal selection, and our own ethics book. Another illogical premise is that a non appraiser can effectively qualify a licensed appraisers work product to make those quality of product distinctions in the first place. The majority of amc companies do not pass cost savings from reduced cost of appraisers services back to the borrowing consumer. The vast majority of amc’s pocket the difference and therefore have a financial incentive to drive down the appraisals fee for variable padded junk profit over and above any supposed contribution they have made. Defrauding consumers does keep a lot of appraisers very busy indeed.

and other who think “cost plus” is a cure all

Pick your favorite AMCs, google their name with the word “affiliates”

Realize that the AMC you are dealing with, might be two, three, four corporations deep in the affiliate list, and the fee is passing from the lender to the mother-ship, with each affiliate in the middle needing to cover expenses for placing the order to the affiliate below them, until it finally gets to the affiliate you are working with.

Rethink. This isn’t 1950 anymore.

Lots of legal language out there, this is just one example;

This clarifies that a lender may collect funds from the borrower for the payment of (i) bona fide loan – related goods, products, and services provided or to be provided by third parties, and (ii) taxes, filing fees, recording fees, and other charges and fees paid or to be paid to public officials. It provides further that a third party provider shall not charge or receive (i) any unreasonable compensation for loan – related goods, products, and services, or (ii) any compensation for which no loan – related goods and products are provided or for which no or only nominal loan – related services are performed. Loan – related goods, products and services are defined to include fees for tax payment services, fees for flood certification, fees for pest – infestation determinations, mortgage broker fees, appraisal fees, inspection fees, environmental assessment fees, fees for credit report services, assessments, costs of upkeep, surveys, attorneys fees, notary fees, escrow charges, and insurance premiums.

NC 1149 Prohibit Predatory Lending: Long Summary

Federal Court Rules Against Fee Markups

Dawn, I work in San Diego County where there is a population of 3.1 million people and 900 licensed appraisers call this county home (all within 30 miles of me). Regionally, the number of licensed appraisers quickly approaches 5,000+. My issue with Dustin often involves his experience from a local level (Rural Idaho / 300+ appraisers state wide), where he in turn creates thoughts and opinions on a national stage (Blogs, Podcasts, booths at Valuation Expo, etc.). What might be typical for him in his entire state, is not typical for 3 times the people just in my single county. In other words, his reality is not the reality for most in this industry, and I truly believe his preachings to the friends he keeps (he does 4 to 8 appraisals per day, reviews work in as little as an hour, we’ve all had raises, etc.), does more harm than help.

Seek the truth.

Dawn, you are certainly entitled to your opinion, just like everyone else. Dustin Harris has not been a good advocate for appraisers, nor the appraisal profession. These are facts that are easily provable. His actions, like his lack of research with this article, speak loud and clear to who he is and what he stands for.

That was my initial thought. But I do see where Dustin Harris is coming from

Again, not necessarily true. In some markets, yes. It’s called capitalism. However, if you provide a good product, clients will come to you and you won’t have a shortage of work. Good appraisers can charge for their work. All the good appraisers I know are slammed with work, and their fees are good…. seek the truth. ?

While the appraiser coach is sponsored by some of those entities, I believe Dustin Harris makes the majority of his income as an appraiser. Since appraising is the cornerstone of ALL his other activities & income, I find it ignorant and shortsighted to merely point the finger and insinuate he’s “working for the enemy.”

I can’t envision a scenario where the sponsorship funds he **might** receive would be sufficiently large to sustain him and his family for the rest of their lives… which is probably what it would take to make him sell out appraisers and appraisals and obliterate all of his businesses. If appraising goes away, so does ALL of his appraisal business and coaching income (as there would be no one left to coach).

So, I read this and I’m like: “Are you freakin kidding?” ??????

No, I’m not affiliated with Mr. Harris in any way, I am not a subscriber to his groups, nor am I on the payroll of any of the aforementioned companies.

For the record, I think he makes a good point. We all know AMCs need to be limited or maybe even done away with entirely. But is anyone truly ready for such a slippery slope of the government capping fees? He’s right, next they could cap appraisal fees….

I’m not decided one way or another on such a bill. But VaCAP also makes some interesting arguments. We’re talking about this openly now.

Personally I think requiring AMCs to be transparent with their fees (ahead of time), would increase public trust as it may allow the borrower and lender to have more control… just a thought.

I’m not for or against the bill. But I think talking about it is wise, (without attacking each other in the process ?)

Thank you VaCap for sharing the facts behind the bill. You guys have been on the forefront of advocacy. Appraisers across the country appreciate everything you do!

i am really disappointed.

Pat

Dustin, in big cities and big population areas (100’s to 1,000’s of licensed appraisers), with TRID regulations (appraisal fees determined in advance), and reluctance to restate to the consumer a need for an increased appraisal fee (complexity, or what ever), in essence there is nearly a 0%  chance to have the fee altered from the original quote to the borrower. By default, when lenders just go to the next dozen, next hundred or next thousand group of appraisers looking for a single yes to the pre-determined fee, the system in place in essence already caps the appraisal fee.

Seek the truth.

The first main component should have been, can the state over-ride the cfpb, how, bcfp, and the answer is: No.

And, can the state change the Truth in Lending Act? Same answer.

Try again.