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...
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...
The current system of bundling appraiser compensation with third-party fees can lead to confusion and frustration for both appraisers and consumers. In their letter to the ASC, NAR highlighted the importance of appropriate compensation for appraisers. They stated that fair and reasonable compensation is critical to attracting and retaining high-quality appraisers, as well as allowing them to invest in their skills and education. However, the current system lacks transparency when it comes to reporting appraiser compensation. The issue lies in the TILA-RESPA Integrated Disclosures (TRID) form, which requires an aggregate appraisal fee to be reported. This means that the fee...
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...
We will call it “AGENT MANAGEMENT COMPANY”. We will ensure that the use of runners is prohibited… Public trust. It’s a real thing. It appears that this recent lawsuit that the NAR LOST has exposed antitrust, collusion and price fixing between agents. I am thinking about creating a new AMC. We will call it an “AGENT MANAGEMENT COMPANY”. We will create a buffer per say between the buyers agent and the sellers agent thereby protecting the buyer and seller. We will have a roster of approved agents nationwide. They will be thoroughly vetted. Routinely background checked. Ensure they are fully...
NAR is conducting a survey and wants to know if you have any concerns regarding property data collectors, if the appraisal fees are higher since the involvement of data collectors, if borrowers are made aware of a fee for the appraisal and a separate AMC fee or were the fees bundled, if the property data collector gave the impression that they were the appraiser, whether you have any safety and privacy concerns with the data collection process, quality of data collected and whether they need to be licensed… In a letter to the Federal Housing Finance Agency (FHFA) regarding appraisal...
The idea of unlicensed individuals being hired off the streets and paid a pittance to video and photograph the interiors of borrowers’ homes, which would include the exact location of valuables and children’s bedrooms, has been unsettling to some. An astute real estate broker recognized the name of a Michigan man awaiting sentencing in an armored-car robbery. The latter had been engaged by one of six companies authorized by mortgage giant Fannie Mae to dispatch so-called “data collectors” to borrowers’ homes. The broker alerted the bank and the National Association of Realtors. New, progressive laws designed to conceal felony convictions...
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....
The results of the NAR appraisal survey show more than half of appraisers reported AMCs to be the greatest challenge in their business with 40% reporting not being compensated fairly. Only 3% of members witnessed or experienced discrimination in an appraisal… NAR Research conducted a survey of all 9,700 appraiser members and 50,000 randomly-selected non-appraiser members to determine the level of impact of appraisals on the current market and member business in terms of cost, turn-around times, and other challenges and to measure member experiences with bias and discrimination in the appraisal process. Highlights of the NAR Appraisal Survey The...
To judge an entire profession by anecdotal evidence is equally both stupid and harmful… The entire emphasis was on “anecdotal evidence” which is not documented or supported. Story after story was told about how appraisers had produced a “biased” report. No documentation and no evidence to support their claims was presented. Folks, after discussing this topic with and learning more about the appraiser who wrote this following essay, I have decided to distribute the essay below as a way to further support what we appraisers do in our work, and to expose the fallacies that have been presented to date...
