Category: Dodd-Frank Act / C&R Fees

Appraisal news for real estate appraisers and real estate professionals regarding Dodd -Frank Act and Customary and Reasonable appraisal fees. News relating to the Appraisal Industry.

Appraisal Regulation Compliance Council Exposes Disturbing AMC Violations 89

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...

Insights from CFPB's Public Comment Period 53

Insights from CFPB’s Public Comment Period

The comment period on the Consumer Financial Protection Bureau’s (CFPB) “Request for Information Regarding Fees Imposed in Residential Mortgage Transactions” concluded on August 2, 2024, with a total of 959 comments received. Upon reviewing some of these submissions, several noteworthy perspectives emerged regarding appraisal fees and the role of Appraisal Management Companies (AMCs). The National Association of REALTORS® (NAR) highlighted the lack of transparency surrounding AMC fees, which are often bundled together with the actual appraisal fee on the Closing Disclosure (CD). This opaque structure prevents consumers from understanding the true cost of the appraisal service and hinders their ability...

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...

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...

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...

Recap of the 4th Appraisal Bias Hearing 9

Recap of the 4th ASC Appraisal Bias Hearing

On February 13th, 2024, the fourth ASC appraisal bias hearing took place. For those who were unable to attend, the video of the hearing has been included below. The hearing was a crucial event for the appraisal industry, and it is important for all appraisers to be aware of the discussions and topics addressed. The panel of witnesses included: David Bunton, President, The Appraisal Foundation E.C. Neelly IV, Executive Director, Mississippi Real Estate Appraisal Board Maureen Sweeney, Principal, Maureen Sweeney, Real Estate Appraiser Ltd. Melissa Tran, Director, Texas Appraiser Licensing and Certification Board Jillian White, Chief Executive Officer, Appraisal Insights...

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...

AMCs Violating TILA and C&R Fee Clauses 111

AMCs Violating TILA and C&R Fee Clauses

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...

Racial Bias Complaint Filed Against Me 47

Seller Filed a Racial Bias Complaint Against Me

So what’s caused the sudden loss of income? Could it be because of the racial bias complaint filed against me by an unhappy Seller…  Fannie Mae accomplished what they set out to do in July 2011, when they initiated their Uniform Appraisal Dataset (UAD) and the Uniform Collateral Data Portal. The goal was to collect enough property data to effectively remove appraisers from the home buying and refinancing process. It all started with Dodd-Frank Act, a several hundred pages Act signed into law by then President Obama, sold to unsuspecting Americans as a protection from the corrupt business practices of...

It’s a Great Time to Leave the Appraisal Profession 169

Leaving the Appraisal Profession

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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