Customary & Reasonable Fees - Appraisers Blogs

The AMCs: Coming Soon to a Lawsuit Near You

AppraisersBlogs — Tue, 20 Jan 2026 13:30:22 +0000

The AMCs built an entire system on silence, and now the quiet parts are being said out loud. For years, the mortgage industry has insisted that appraisal management companies are the guardians of independence, the compliance buffer that keeps lenders and appraisers at a safe distance. Yet 2025 has delivered a storyline that feels more like satire than industry narrative. Borrowers are suing, judges are listening, and the AMC business model is beginning to look less like a safeguard and more like a very expensive middleman with a very opaque invoice. The first shock came from California, where the Timmins...

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NAR Calls Out Unregulated Middlemen: A Wake-Up Call for FHFA

AppraisersBlogs — Thu, 02 Oct 2025 12:30:27 +0000

When unregulated middlemen run the show, appraisers get ghosted, consumers get duped, and regulators get a velvet-gloved slap from NAR. In a housing market that demands clarity, Appraisal Management Companies, or AMCs, continue to operate like the magician’s assistant, always present, rarely transparent, and somehow still part of the act. But the National Association of REALTORS® (NAR) just handed the Federal Housing Finance Agency (FHFA) a letter that reads less like a polite memo and more like a velvet-gloved slap. It’s a bold call to rein in AMC antics and restore dignity to the appraisers who keep the system honest....

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Bye Bye AMC: A Script to Sideline Appraisal Middlemen

AppraisersBlogs — Thu, 15 May 2025 12:30:17 +0000

The “Bye Bye AMC” script, a clever SQL solution, aims to disrupt Appraisal Management Companies by automating merit-based appraiser assignments, slashing AMC fees, and boosting transparency in real estate valuations. In the high-stakes arena of real estate appraisals, where precision tangoes with red tape, a sharp SQL script named “Bye Bye AMC” is poised to shake up the status quo. Crafted by Chase Pursley, founder of Appraisal Inbox, this code isn’t just a string of queries — it’s a potential death knell for Appraisal Management Companies (AMCs) that have long profited by squeezing appraisers, meddling in valuations, and padding their...

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

Desiree Mehbod — Fri, 02 May 2025 12:30:49 +0000

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), I’m here...

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

Guest Author — Fri, 25 Apr 2025 12:30:13 +0000

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...

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AMCs Overcharging Consumers? Morgan & Morgan Investigates

AppraisersBlogs — Fri, 14 Feb 2025 13:30:12 +0000

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...

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The Great Debate on Appraisal Fees

Isaac Peck — Mon, 28 Oct 2024 12:30:09 +0000

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...

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Appraisal Regulation Compliance Council Exposes Disturbing AMC Violations

AppraisersBlogs — Fri, 30 Aug 2024 12:30:34 +0000

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...

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Fight Unfair AMC Practices – Leverage State Authorities

AppraisersBlogs — Wed, 14 Aug 2024 12:30:38 +0000

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...

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Lack of Fee Transparency: Exposing the AMC Exploitation

Desiree Mehbod — Wed, 31 Jul 2024 12:30:07 +0000

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...

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Exposing Predatory AMCs

AppraisersBlogs — Fri, 14 Jun 2024 12:30:39 +0000

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...

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CFPB Crackdown: Unfair Practices Hurting Consumers

Guest Author — Wed, 05 Jun 2024 12:30:07 +0000

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...

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AMCs Billing Scheme, Hidden Profits & Deceptive Practices

Guest Author — Wed, 07 Feb 2024 13:30:29 +0000

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...

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AMCs Violating TILA and C&R Fee Clauses

AppraisersBlogs — Thu, 01 Feb 2024 13:30:44 +0000

Fellow Appraisers, the appraisal industry has been facing a major issue with AMCs violating the Truth in Lending Act (TILA) and the Customary and Reasonable fee clauses. This has not only caused harm to consumers but also to appraisers who are struggling to make a living. Despite efforts to bring this issue to light, it has been largely hidden from the public and regulators. However, it is time to change that and reveal the truth about what is really happening. To do so, we need to gather more data and evidence to establish a pattern of violations for these bids...

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Leaving the Appraisal Profession

Guest Author — Wed, 20 Sep 2023 12:30:02 +0000

It’s a Great Time to Leave the Appraisal Profession. I can hear the chorus of my fellow appraisers rising up in disagreement with me. I envision many of them screaming, “But I love being an appraiser”! Yeah, I hear you. I loved being an appraiser too. Let’s not consider what we were but what they want us to become. First, ask yourself if you are still making a livable wage. I’m not and instead of blaming myself, I started running the numbers. In, my high value market, 18% of the solds were cash sales. No appraisal required on those! Values...

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AMC Engagement Letter: Appraisers Do Not Include Your Invoice

VaCAP Board — Fri, 28 Jul 2023 12:30:23 +0000

File the complaint against the AMC yourself OR Forward the engagement letter to VaCAP to file on your behalf. At the recent Virginia Appraisal Board Meeting on Wednesday June 28th, a discussion occurred about Appraisal Management Companies prohibiting appraisers from including their invoices with the appraisal report. The overall consensus of the Board Members was this practice could be a violation of Virginia Appraisal Management Company Statute § 54.1-2022 B. “B. The appraisal management company shall not prohibit an appraiser from disclosing in the appraisal report the actual fees charged by an appraiser for appraisal services, and shall otherwise comply...

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Look in the Mirror

Mark Skapinetz — Mon, 27 Feb 2023 13:30:14 +0000

The phrase “take a look in the mirror” is a common idiom used to encourage self-reflection and introspection. It is a powerful statement that can evoke a range of emotions and reactions from individuals, from contemplation to defensiveness. At its core, the phrase is a call to examine oneself honestly and objectively. It asks us to step back from our assumptions, biases, and preconceptions and consider our behavior, choices, and beliefs in a critical light. When we take a look in the mirror, we are forced to confront our flaws and shortcomings, but also to recognize our strengths and achievements....

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‘Opportunity’ to Work for Free is Not a Plan

Dave Towne — Thu, 23 Feb 2023 13:30:50 +0000

I gave this ‘opportunity’ further critical analysis in terms of time spent versus the fee income potential. Appraisers, I’d like to disclose a personal ‘opportunity’ that was presented to me last fall, early winter. A company with AMC roots was, or is, recruiting people to become “property inspectors” with the resulting reports potentially fed to other appraisers who do HYBRID, or maybe even DESKTOP reports. The GSEs never intended the DESKTOP report to incorporate separate ‘property inspections’ from a hired third party, but that’s been the evolution because they just look the other way. Last fall, due to the slowdown...

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“Valuable” Advice From an AMC

Dave Towne — Mon, 06 Feb 2023 13:30:18 +0000

The person who espouses this super valuable ‘advice’ does not have an appraiser’s license… Appraisers, if you think I’m serious about the message subject line, please reconsider! It’s time to actually call out an AMC who’s encouraging appraisers to ‘lower their fee’: Valuation Connect This outfit sent out a ‘newsletter’ to appraisers, part of which says this: “My advice would be to make adjustments based on the market. Some examples in a slow market would be adding a new county or zip code to your coverage area, lowering your fee for a product, or adding a new product to your...

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AMCs Take a Sizable Cut of the Appraisal Fee

Mark Skapinetz — Wed, 05 Oct 2022 12:30:29 +0000

It still proves my point: Appraisal Management Companies take a sizable Cut of the appraisal fee… It was March 28th, 2018 that I wrote my very first blog post entitled “What’s not in your wallet?” where I went into great detail about how Appraisal Management Companies or AMCs get paid and how the consumer is not aware of the fact that the AMC is taking much of the fee while finding the cheapest and fastest appraiser. In that blog post, I gave many examples of the abuse appraisers and consumers are absorbing by these Appraisal Management Companies. How one borrower...

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