Obviously yes, and the points were clear.

Disregard for established guidelines, the rule of law, and basic ethical principles is a hallmark of many amc’s.

Thank you for playing. Please come again.

ZZZZZzzzzzzzzzzzzzz. Is there a point?

It’s probably your browser or cross platform something or another. Here is the link from above.

https://www.regulations.gov/document?D=CFPB-2020-0020-0001

That’s a lot to go through… How are they going to season anything when they lend on a fractional reserve basis, keeping the volume going because of the immediate saleable opportunity the gse’s provide? Seeing them have to hold the notes for 3 years would appear to be a game changer on multiple fronts.

The burden of proof is on amc’s to prove they are worth anything or do help the process. 10 years later they have still been unable to justify their own independent billing, and still have not found broad majority acceptance among the licensed appraiser community. The amc’s have a financial incentive to reduce the appraisers fee for variable amc profit, while simultaneously pushing the consumer price higher and/or never returning cost savings from reduced cost of appraisal services to consumers. That’s why 3 out of 4 appraisers nationally refuse to provide service for amc’s.

The management rule, one must not provide a thing of value. FDIC rules on appraiser selection confirms this principal, one must not provide a thing of value to be the preferred vendor assigned an appraisal order. Appraisers whom discount for amc’s which do not utilize cost plus are clearly providing a thing of value to amc’s, and they are rewarded with the lions share of work assignments. The amc model with co mingled billing promotes excessive outsourcing, fewer professional trainees, entices the use of runners, promoting automation on every turn. For any amc argument, first clearly first distinguish and prove if the amc bills for their services separately or has co mingled billing with the appraiser. Without someone else to dump risk onto, such practices would never have been broadspread in the first place. If a mortgage banker engaged in such billing practices where they charged consumers much more than the actual service was billed for by the provider, it would be a clear violation of junk fee rules and could land them in prison. Ethics in appraisal billing, too inconvenient for some to consider.

Let’s go back to “stated income” and non verification of funds & employment verification. 2008 again. If you can breathe, your approved.

Our society, our government, our professions and may more are tied to keeping home ownership and probably-maybe expanding it to over 65% of the populace owning their own homes. Home ownership IS a great incentive to better citizenship.

Many Presidents and their legislatures have encouraged it, as evidenced by the FHA, VA, and the Farm home loan programs.

Have the populace tired of those inspired government programs????

Real Estate had always been a local thing, some arena’s prospered, some slowed, some re-planed and some failed.

local bankers-lenders knew, and maybe told their appraisers