Category: Customary & Reasonable Fees

The Perfect Storm: A Veteran’s Take on a Dying Craft 75

The Appraisal Profession’s Perfect Storm: A Veteran’s Take on a Dying Craft

The new UAD form, the AMC fee gouging, the waivers, the false bias claims – it’s a perfect storm of assaults.  I’ve been an appraiser since 1993, back when fax machines were cutting-edge and the internet was a clunky novelty. Over three decades, I’ve seen this profession weather storms — economic crashes, regulatory overhauls, you name it. But what’s happening now? It’s not a storm; it’s a tsunami. Our industry is hemorrhaging talent, drowning under false accusations, and getting squeezed by corporate greed and bureaucratic overreach. As someone who’s stubbornly refused to bend the knee to Appraisal Management Companies (AMCs),...

AMC / Appraisal / Appraisal Management Companies / Appraisal News / Appraisal Organizations / Appraisal Subcommittee

A Cry from the Appraisal Trenches: The Fall of GSE Oversight 75

A Cry from the Appraisal Trenches: The Fall of GSE Oversight

That could bring our best and brightest back to GSE lending, leveling the playing field with fairer work distribution.  Picture this: a system built to protect homeowners, backed by taxpayer dollars, now teetering on the edge of betrayal. The regulatory framework governing Government-Sponsored Enterprises (GSEs) was once a fortress of consumer protection, transparency, and fairness. As an appraiser, I’ve watched this fortress crumble. The rules imposed on GSEs and their partners—our trade-off for their congressional charter—have been chipped away through years of cunning maneuvers by trade groups and stakeholder interests. What’s left is a hollow shell, far removed from the...

AMC / Appraisal / Appraisal Management Companies / Appraisal News / Appraisers News / Automated Valuation Models

AMCs Overcharging Consumers? Morgan & Morgan Investigates 48

AMCs Overcharging Consumers? Morgan & Morgan Investigates

Morgan & Morgan, a prominent law firm, is currently investigating the practices of Appraisal Management Companies (AMCs) and their potential role in driving up the cost of appraisals for consumers. The firm is actively seeking input from individuals who believe they have been overcharged or misled about the allocation of their appraisal fees between the AMC and the appraiser. At the heart of this investigation lies the concern over a lack of transparency, inflated costs, and questionable value that AMCs bring to the appraisal process. The Appraisal Regulation Compliance Council (ARCC) has conducted extensive research on this matter, revealing alarming...

AMC / Appraisal / Appraisal Management Companies / Appraisal News / Appraisers News / Customary & Reasonable Fees

The Great Debate on Appraisal Fees 32

The Great Debate on Appraisal Fees

She included several different fee split examples indicating AMCs retained as much as 70 percent of the total appraisal fee paid by the borrower, which prompted her to stop working with AMCs because of the lack of transparency.  The appraisal industry is abuzz with a discussion about appraisal fees. The Consumer Financial Protection Bureau (CFPB) recently issued a Request for Information Regarding Fees Imposed in Residential Mortgage Transactions [Docket No. CFPB-2024-0021] in which it solicited feedback from the public and industry stakeholders on the fees charged to consumers by mortgage providers and related settlement services. The CFPB framed it as...

AMC / Appraisal / Appraisal Management Companies / Appraisal News / Appraisal Organizations / Appraisers News

Appraisal Regulation Compliance Council Exposes Disturbing AMC Violations 102

Appraisal Regulation Compliance Council Exposes Disturbing AMC Violations

The Appraisal Regulation Compliance Council published a detailed breakdown to the CFPB, which showed the median average AMC fee being charged to borrowers amounted to a staggering 65% of the total appraisal fee, with one AMC extracting as much as 84% in pure profit. The Appraisal Regulation Compliance Council (ARCC) is a crucial non-profit organization that specializes in providing fact-based research and expertise on the complex web of appraisal regulations and compliance issues. Driven by a non-partisan mission, ARCC has spent the last two years diligently collecting, vetting, and organizing comprehensive data on lender appraisals conducted by Appraisal Management Companies...

AMC / Appraisal / Appraisal Management Companies / Appraisal News / Appraisers News / CFPB

Fight Unfair AMC Practices - Leverage State Authorities 32

Fight Unfair AMC Practices – Leverage State Authorities

Alarmed by predatory practices among AMCs, a peer has drafted letters urging appraisers to call on state authorities to address unfair AMC conduct and potential regulatory violations.  As appraisers, we have faced an ongoing challenge with Appraisal Management Companies (AMCs) offering fees that are well below the customary and reasonable rates for standard appraisal assignments. This practice has created a troubling trend of “bid wars” where AMCs pit appraisers against one another, driving down fees to unacceptably low levels. In response to this issue, a peer has provided two draft letters that can be easily modified and used by other...

AMC / Appraisal / Appraisal Management Companies / Appraisal News / Appraisers News / Customary & Reasonable Fees

Lack of Fee Transparency: Exposing the AMC Exploitation 71

Lack of Fee Transparency: Exposing the AMC Exploitation

By keeping the borrower in the dark about the true cost of the appraisal, the AMCs are able to charge exorbitant prices and pocket the difference (as shown in Figures 1 through 10), exploiting the consumer’s lack of knowledge.  Thank you for the opportunity to comment on the Consumer Financial Protection Bureau’s Request for Information on Fees Imposed in Residential Mortgage Transactions. The growth of Appraisal Management Companies (AMCs) in the wake of the 2008 financial crisis was driven by a well-intentioned but ultimately misguided belief that they could help “ensure the integrity and independence” of property valuations. The reasoning...

AMC / Appraisal / Appraisal Management Companies / Appraisal News / Appraisers News / CFPB

Exposing Predatory AMCs 49

Exposing Predatory AMCs

Exposing the inner workings of these predatory AMCs and their corrosive influence on the housing market.  Cindy Chance’s recent comments about the concerning practices of some appraisal management companies (AMCs) have struck a chord with many in the real estate valuation industry. Chance is shedding light on the troubling ways in which certain AMCs have come to wield significant power and influence over the appraisal process, often to the detriment of both appraisers and the public. The growth of AMCs in the wake of the 2008 financial crisis was driven by the misguided belief that they could help “ensure the...

AI / AMC / Appraisal / Appraisal Institute / Appraisal Management Companies / Appraisal News

CFPB | Bureau Crackdown: Unfair Practices Hurting Consumers 23

CFPB Crackdown: Unfair Practices Hurting Consumers

Bureau is currently investigating various fees associated with obtaining a loan, with the goal of identifying any that may be particularly burdensome or concerning for borrowers. As we all know many AMCs are not paying Customary & Reasonable fee as required by TILA. They have consistently pushed down the pay of Appraisers while making undisclosed profit off consumers and prioritizing cheapest and fastest over quality and competency. The CFPB has been in communication with individuals behind the scenes and are concerned with what has been shown enough to include AMCs in their data collection process. Now is the time to...

AMC / Appraisal / Appraisal Management Companies / Appraisal News / Appraisers News / CFPB

AMCs Billing Scheme, Hidden Profits & Deceptive Practices 82

AMCs Billing Scheme, Hidden Profits & Deceptive Practices

Appraisers who do not agree to their hidden billing methods are excluded from the majority of the GSE lending marketplace for appraisal orders.  Appraisal Management Companies (AMC’s) do not pass on cost savings for reduced appraisal services to consumers. Instead, they keep the savings for themselves without disclosing the amount to the consumer or the appraiser. What should have been cost savings for the consumer are pocketed by the AMC in secret. This is considered a junk fee or unearned fee billing scheme under current law. Appraisers who participate in this system are in violation of The Management Rule of...

AMC / Appraisal / Appraisal Management Companies / Appraisal News / Appraisers News / Customary & Reasonable Fees

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