Dodd-Frank Act / C&R Fees - Appraisers Blogs

The Board Has Spoken, and AMCs Should Pay Attention

AppraisersBlogs — Mon, 06 Jul 2026 12:30:02 +0000

The Board handled this case with the same patience appraisers have when an AMC sends “preferred comps” from another planet. Virginia’s Real Estate Appraiser Board delivered a message at its June meeting that was impossible to miss. An attorney appeared on behalf of Financial Asset Services and Brandon Sison, asking the Board to reconsider the discipline handed down in March. The request arrived without the AMC or Sison themselves, which already set an interesting tone. When you ask a regulatory board to undo a suspension, showing up in person is usually a good start. The March decision was clear. The...

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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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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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The Shadowy AMC Fees Draining Billions from Homebuyers

AppraisersBlogs — Thu, 09 Jan 2025 13:30:46 +0000

The hidden costs of appraisal management companies (AMCs) in the real estate industry have faced growing scrutiny, as highlighted by a recent Business Insider article titled “The Hidden Middleman who cost homebuyers $12 billion dollars and counting.” The article examines the opaque practices of AMCs, which frequently charge exorbitant fees that can exceed the amount paid to the appraiser. As highlighted by former Appraisal Institute CEO Cindy Chance, this issue has faced significant resistance from entrenched interests, mirroring the challenges faced in other industries such as the pharmacy benefit manager (PBM) sector, which ultimately led to an FTC investigation. The...

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The New Con: Hybrids, Waivers & AMCs Threaten Public Trust

VaCAP Board — Mon, 16 Dec 2024 13:30:39 +0000

Hybrid Appraisals, Appraisal Waivers and Appraisal Management Companies are the new Con. Last month marked the 7-year anniversary of Appraiser Fest. The conference was truly like nothing that had been done before. It was organized by appraisers for appraisers. The agenda was more about bringing the profession together and protecting the public trust. Appraiser Fest was not about promoting the profit of others at the expense of appraisers; nor was it about hiding the unchecked facts of fraud and ill doings against consumers. It was about public awareness and trust. It all started with a renewed sense of energy with...

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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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Insights from CFPB’s Public Comment Period

AppraisersBlogs — Tue, 13 Aug 2024 12:30:20 +0000

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...

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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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Recap of the 4th ASC Appraisal Bias Hearing

AppraisersBlogs — Wed, 28 Feb 2024 13:30:47 +0000

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...

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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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Seller Filed a Racial Bias Complaint Against Me

Guest Author — Tue, 07 Nov 2023 13:30:08 +0000

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...

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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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AMC Fee Impact on Appraisal Fee

AppraisersBlogs — Thu, 01 Jun 2023 12:30:54 +0000

While the borrower was charged $695 for the appraisal, the appraiser was only paid $301. The AMC fee was $394. We often hear complaints from GSEs and lenders that appraisal fees are too high, hence the push for modernization. Yet they fail to acknowledge that this is due to an overly bloated middleman – the appraisal management company (AMC). As a consumer, you should be aware of the potential for being fleeced on appraisal fees. It’s possible that you could be paying more than double what the appraiser is receiving for actually doing the work, with the excess going to...

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Dear Representative, FNMA Has Gone Rogue!

AppraisersBlogs — Mon, 27 Mar 2023 12:30:24 +0000

Dear representative, waiving/eliminating property appraisal for lending purposes is wanton recklessness. Fannie Mae’s decision to waive/eliminate property appraisal for lending purposes is nothing more than wanton recklessness that could have serious repercussions in the future. The truth of the matter is that appraisals are an essential part of any mortgage transaction and should not be taken lightly or eliminated without due consideration. Without them, there can be no assurance as to whether a homebuyer will get what they pay for or if lenders will make bad investments with their money. In short, waiving/eliminating property appraisal requirements puts everyone at risk...

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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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