The Expert Only Gets 10% of Fee

Clear Capital Evaluations: The Expert Only Gets 10% of FeeIn the Appraisal World, The Expertise Only Gets Ten Percent of Fee

An Indiana state certified appraiser based in Indiana who is also certified in other states including Georgia did an evaluation of a number of properties in Georgia. The “appraisal fee” was $250 but the AMC (Clear Capital) got $225, and this appraiser got $25 for each evaluation. I’ve blocked out the specifics of one of the orders except for the fee – in this disclosure form required in Georgia.

Clear Capital ClearVal Evaluations Fee

In other words, the administrative fees for Quality Assurance, Broker/CMA fee, Home Data Index Fee (whatever that is) and of course, the all-important “Data entry fee” is many multiples more important than actual valuation expertise.

Key Points:

  1. The administrator (Clear Capital) gets 10x more to do administrative work than the valuation expert.
  2. The valuation expert is not a valuation expert because real local market experts can’t afford to accept evaluation requests. These evaluation assignments are built on a fraudulent premise that credible experts will do them*.
  3. The public perception of an appraiser gets lumped in with evaluation producers, doing significant harm to the appraisal industry’s reputation and violates the premise that these assignments are effective in protecting the public trust.

*Note: You can’t become an actual market expert working for a $25 evaluation fee, especially from thousands of miles away – it requires shortcuts to do so.


“Maintaining the public trust” is ignored with the evaluation product which is why the Appraisal Institute was booted from TAFAC (the non-profit side of The Appraisal Foundation) – I’ve mentioned this before – AI National refused to sign off on the mission statement of TAF that refers to protecting the public trust.

TAF Vision Statement To ensure public trust in the valuation profession.

TAF Mission Statement: The Appraisal Foundation is dedicated to promoting professionalism and ensuring public trust in the valuation profession. This is accomplished through the promulgation of standards, appraiser qualifications, and guidance regarding valuation methods and techniques.

Please absorb the ramifications of this situation to the boots-on-the-ground appraisal professional:

  • Someone based in Indiana, arguably not “just over the line” was hired to do a number of evaluations in Georgia for $25 each, presumably very quickly.
  • Borrowers relied on this “market expertise” for a $250 fee and used this expertise (from someone who only got 10% of the fee) to make decisions that could damage their interests (bring in the lawsuits!).
  • The Appraisal Institute has continued to hard-sell Congress and state legislatures on giving the ability of certified appraisers to flip the “on/off” switch of their license to do these $25 evaluations even though most of the AI residential membership – aside from AI Institute blind loyalists – would tell you that the three “key points” above will happen. In fact, top executives at AI National give the impression that their own residential members are desperately clamoring to do $25 evaluations yet, in reality, AI National never actually sought real input from their own residential membership other than from wanna-be insiders.
  • A living breathing human certified appraiser actually accepted this assignment and was able to sleep at night.
  • Clear Capital got 10x the fee the actual valuation expert did and was clearly super talented at data entry – presumably demonstrating a skill more vital than the valuation.

Why are evaluations being allowed to normalize in the industry? Their reality is defrauding the public of expertise they think they are paying for and tarnishing the contribution and risk management the qualified appraiser provides to the mortgage process. It’s not a difficult concept to grasp – even ten percent of it. Read more »

Jonathan Miller
Jonathan Miller

Jonathan Miller

Jonathan Miller is President and CEO of Miller Samuel Inc., a real estate appraisal and consulting firm he co-founded in 1986. He is a state-certified real estate appraiser in New York and Connecticut, performing court testimony as an expert witness in various local, state and federal courts.

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33 Responses

  1. Ross Grannan on Facebook Ross Grannan on Facebook says:

    Can’t stand clear capital, the only work I ever saw from them was from Chase, birds of a feather

  2. Vincent Ralph Simon on Facebook Vincent Ralph Simon on Facebook says:

    Dumped them years ago, blocked the emails and they still call .

  3. Avatar Frank says:

    GA has established C&R fees. Any chance the Title Co mistakenly transposed the numbers? What was the service performed by the Appraiser? Last question, why would any Appraiser in their right mind accept the outlined fee conditions?

    • Baggins Baggins says:

      There were no mistakes, it’s real, and a side of fraud to go with it, copied photos, copied maps, patterns of data entry deficiency, etc. A major real estate firm works closely with amc’s and appraisers licensed in multiple states, churning remarkable numbers of evals out.
      Per field review, 1m, and demins; These numbers are absurd. The poorest Americans have no protection. Every single loan should require a full appraisal. The notion the appraisal only serves the lender, and is therefore something they can simply choose to opt out of is false. The appraisal is a vital application of checks and balances systems, such a beneficial service should be mandatory for all. Or they can pay cash. No exceptions.

    • Avatar wontobey says:

      Frank, more info covered in this article


    • Frank, click the graphic under the article where I had the entire reports in question posted. Check the pictures and compare between the two reports. Check the maps. Best of all, check the as is and as repaired values reconciliation. Check to see that an opinion of market value IS being offered but not by an appraiser!

      Jonathon, I blame AI for promoting Evaluations, but these particular turds are strictly the product of deceptive service providers and software whores that are paired with dishonest real estate brokers and out of state volume guaranteed appraisers. TAF has done NOTHING to settle the evaluations / hybrids issue except to tell people what they want to hear “Yes, they can be done.” all the rest is ignored. (Though their new USPAP DOES make it so much easier now to ignore even more standards).

      Read related article on India BPOS – it is the same thing… only these are done for only $10. No sense wasting that extra 7 1/2 % the AMC could be raking in! Pay sharp, hard working Slum Dog Millionaire Contestants that LOST, 2 1/2 % rather than that outlandishly high 10% an American appraiser would charge!

      Research the “broker” that ostensibly did the field inspections. He owns over a dozen offices in three different states. By all appearances from his website highly successful brokerage. I do not believe he drives around doing his own BPO inspections. So, if that’s the case, WHO or WHAT did the field inspections that the appraiser deemed to be a ‘credible’ source?

      These hybrids were in support of purchase financing. Since when does Georgia Law allow a broker to perform an appraisal with a fair market value opinion shown? The report SAYS its an appraisal. These two illustrative reports were on Non FRTs but the BPOS from Bangalore were FNMAs. Sate and federal regulators across America should be chomping at the bit over this.

      Instead, ALL seem to be waiting for the winds of outrage to subside so they can get back to business as usual.

  4. Avatar Chris says:

    For $25.00…..The appraiser sold his signature….probably just glanced at the report.

    Maybe didn’t even do that…Maybe someone stole the signature.

    Wait till they start seeing the losses…how many asinine gimmicks have we all seen over the past 3 decades from these companies trying to get faster appraisals that MAKE their deals work….

    We all know why they want faster… the borrower does not have time to walk…..and get a better loan somewhere else !!!

    • Baggins Baggins says:

      When they win, it’s an appraisal.  When they do not win, it’s merely a cma.  Just guessing but come on, what else could be going on?  Out of the 375,000 of these per the companies own admission, how many received field reviews?

  5. Avatar Diana N. says:

    Absolutely disgusting. Shame on those”appraisers” and I use the word loosely, that are that desperate to take these assignments.  You are a discredit to our profession and to the reputation of honest, hard working appraisers all over the country.

    • Baggins Baggins says:

      Still waiting to see how much the realty agent was paid.  From the wording this may be part of the 225 fee cut.  Now the realty agent is getting paid out of the appraisers cut as well.  More savings!

    • Avatar Diana N. says:


    • Avatar don says:

      The VA loan is a recourse loan, when the veteran defaults and the equity is lower than the value of the loan balance the veteran is liable for the deficit.

      How would the courts the state, federal politicians, and the laws work.

      Clear Capital and the Corporate world wood loose and it would not be a contest.

      Appraisers are not the only solution for the the real estate loan industry, appraisers are no more honest than other pro’s.  Legislating, issuing rules and licensing have not been effective, and they’ve been tried over and over again.

      Appraisals are an excuse most effectively used in prosecution.  Fees are higher for appraisers in judicial hearings

  6. Avatar Pam p. says:

    Veterans deserve nothing less then a USPAP compliant appraisal completed and inspected by a State Certified appraiser. This is crap.

  7. Avatar Roy B says:

    I used to get mad. I used to get fired up when this kind of s%*t happened. What is the point? We have no control; we won’t do what is necessary to take control. It’s all about us, not them. We don’t have a straight up charismatic leader who will tell us, just say no, so we don’t. I used to think it was them. Now I know it is us. We are the ones that need to put rules and regs in place, not the stuffed shirts. We, by definition of the job we do are the ones guarding the public trust, not the lending industry. When I listen to them then watch what we do, we look like Barney Fife who is allowed no bullet in his gun. USPAP is a document that changes each year. The update class only points out that the changes are so miniscule and unimportant that they have no effect on the industry and in fact related industries do not have to abide by the rules anyway, only appraisers. FIRREA was to end economic meltdowns. How did that work out in 2007-2008?. We all sign off as to being USPAP compliant. In preparing for a court testimony, I told the attorney deposing the opposing appraiser to ask questions about USPAP to see if he had any understanding. He wasn’t too sure about what USPAP said, but he had heard of it. This is a certified appraiser. How about you? Do you know what USPAP says? You sign off on your reports as USPAP compliant. I would guess that you understand without being able to quote. If not, why do you sign off? It’s so you eventually get paid, right? Its all about the money, a pot that diminishes whenever the lending / AMC arms can make it happen.

    I’ve been a fee appraiser for most of 38 years. I have seen massive changes from 1979 forward. The question is, has the result in the outcome of an appraisal improved over time and is it the political / lending institutions heavy hand on our industry responsible for ANY of the improvements? Who knows? What organization has conducted studies on the quality and outcome of appraisals for the year following the requirement of FIRREA, of USPAP, and the subsequent years following the annual changes to USPAP? WE are the experts. WE are the only entity that can police our profession and it’s contributors. And nothing will ever change until we as individuals and the appraisal profession in general JUST SAY NO!

    If you respond to that email blast to compete for cheapest and fastest, you are the problem. If you don’t look at the big picture but are satisfied with a shrinking fee vs. scope, you are the problem. If you don’t actively force the bad appraisers out, you are the problem. We need to focus on the quality of our peers. The quality of our work product will naturally follow. I’m the problem too. At 71 years old I no longer really care about a profession that does not care about itself or its professionals. But I do say no. All the time. I saved money while it was busy so that I don’t have to panic now that it is slowing down in my area. All you fastest and cheapest email blast worker bees don’t have to compete with me. But its us against them; them is winning. But it is us that let it happen and probably always will; that has been true my whole career.      

    • P O O P!!! I thought I was being charismatic. Oh, unless ya meant the other part.

      Roy excellent points and all true. I got in about 7 years after you did. The days of three handwritten ‘comps’ with no more than an address and qualitative comments with a number on the bottom as letter appraisals had almost completely ended by then (circa 1986).

      I saw a distinct upgrade in quality after USPAP was finally implemented around 1991 – two years after being passed. Appraisers all across the country seemed to be trying to comply under the silly notion that government was serious about cleaning up the profession.

      By 2000-2002 it seemed the pressure was on again to look the other way or only reconcile to high ends orf ranges again. USPAP had become a moving target so no one bothered to ‘near-memorize’ it anymore. We KNOW by 2007 that low end AMC pressure had pretty much wiped out quality and being allowed adequate time for completion.

      Lets not forget when FDIC did forensic reviews on over half million Countrywide and WAMU appraisals they found 90% were deficient (non compliant); 95% were over valued, and 97% were egregiously deficient (whatever that means).

      HVCC was a knee jerk reaction that only showed more legislators how to get into the feeding trough line AMCs were putting out.

      We are out of the Great Recession now in nearly all categories in most areas, but that does not mean 100% of old values have recovered. My own property was $650k in 2006; bought by us for $325k as an REO and if I believe my own ability to objectively analyze value it should be superficially somewhere around $450k+- today. Zillow would say over $500k to $550k. Point being is that we have not recovered all lost value; though Id still argue we are close to what real value should be (in my area) without insanity being the main motivator.

      No appraisal or a PIW? I could easily make a stacked deck case for $500k and accept a ‘cut value’ down to $450k. OR an 80% LTV cash out refi and walk away with $80k. No need to worry about ANY of those non apparent issues that I also know COULD cost me or subsequent buyers another $50k to cure/fix, right?

      Roy the sad part is that there are so many low fee form fillers out there that even with an appraisal my property would probably slip through cracks it should not. If morality and integrity were not factors, I could pretty well guarantee it.

      So, overall our professional quality has diminished I think. TAF and states have done NOTHING to improve it. Nothing. Federal legislators have done nothing meaningful to improve appraisal conditions or simply “Public Trust” in the appraisal process. They left their Congressionally mandated American Real Estate Appraisal path and got lost somewhere in the Enchanted IVS Forest.

      Roy one exception; the American Guild of Appraisers is and has been unrelenting in its efforts to protect and educate appraisers, and to fight for necessary appraisal reforms. We are mainly volunteers. We could certainly use the help of more folks like yourself. Join us. contact

      Whether you join AGA or not, keep writing and sharing your views. (but join anyway!)

  8. Avatar TruthBTold says:

    Clear Capital = Super Pimps! They contacted me to join their panel when they first got started. I signed up not knowing they were adopting the “we make as much money, or more than the appraiser” concept. I never took an assignment but bidded on a few just to see what would happen. Then they came out with an “appraiser Newsletter” showing how much they support appraisers and how big of an advocate they are! I was more upset with the appraisers that were accepting this work and liability to the point where I posted in the comments section of their newsletter, trying to point out how much work and liability they were taking on for chump change. One offer that comes to mind was a purchase appraisal for $4,800,000 and their suggested fee was $275.00

  9. Avatar Fritz Vogel CREA,CRS,CEI,GRI NY Cert. Apopraiser says:

    Why bother do Clear Capital work at all? Are you a starving Appraiser? They are really “transparent” to appraisers but the public has no clue what is right and wrong, nor do they care….They care about “THEIR” deal, if they make their value or if the property “Passes” inspection. That’s it. Credible value & Credentials don’t mean squat. They ONLY thing WE can do is DON’T work for AMC’s like this…………

  10. Juan Zamudio on Facebook Juan Zamudio on Facebook says:

    This is common in South Florida, Full of ignorant appraisers who sell themselves for pennies…. Scumbags

  11. Andy Ricks on Facebook Andy Ricks on Facebook says:

    WTH works for $25? I decline all their work.

  12. Avatar Loidene says:

    I have a client who has just signed with some sort of Clear Capital technology for underwriters. The client is charging the appraiser a fee of $13 per order. Plus there is a $9.99 upload fee to my clients preferred website. The Clear Capital technology, as it was so nicely put to the appraiser’s, “will provide underwriters with real time analytics and insight into the real estate market and valuations, expanding their professional expertise on condition, quality, and value of residential properties”! Really!!!! So now we are expected to pay for technology to educate the underwriters? Does anyone know what this technology is?

    • Avatar Bill Johnson says:

      That client would be Guaranteed Rate Loidene. A good company, but the spin I was told is that it should cut down on appraiser conditions, and thus save us time. The problem with that logic however, is that I’ve done 10 assignments for them over the past 30 days, and I’ve had NO conditions. Those same 10 assignments this month, will set me back $130 at $13, or $230 counting the original $9.99. All of this with their due dates being moved up to 3 to 4 days (my turn time from assignment 24 to 48 hours), instead of their company policy of 7. They said because its slow, we should be able to work faster. Welcome to the life of a CA big city appraiser.

      Seek the truth.

      • Avatar chris says:

        Bill….are you saying you do appraisals for $275.00 ???

        • Avatar Bill Johnson says:

          No Chris, to my knowledge Guaranteed Rate handles all of their appraisal orders in-house, and thus I receive my work directly from them with no AMC involvement. Last month, my fees ranged from $450 to $600 for what I would consider run of the mill assignments. Big picture, much of my work is by way of the VA which pays $600.

          Seek the truth.

      • Bill Johnson, ..certain client changes do not warrant civil responses. This is not a client that is worth working for anymore. In fact, they have dropped themselves down to being a client with policies that IF followed by appraisers put them at much greater risk of making an error. Even great appraisers, like I believe you to be from past posts.

        I think my response would be to point out that their shortened turn around time of only three days does not (always) allow adequate time for necessary research or cold review of completed work. Typically five to seven days is necessary for this. Further, that as a great appraiser, you are NOT slow enough to have to accept downward price pressure to below reasonable fees for the area. They need to comply with Dodd Frank’s reasonable and customary fee requirement.

        Instead of encouraging appraisers to cut corners by unlawfully coerced lowered fees, they should be encouraging appraisers to take MORE time to complete work so that errors are reduced and report quality is maximized. I’d remind them of ALL the things THEY are required to do to assure their LENDER clients are in compliance with federal regulations and ask how their new policies achieve this?

        I’d do it in writing and be sure to send a cc to The Appraisal Subcommittee; the FFIEC and to Congress Member Maxine Waters as Chairman of the House Committee on Housing and Finance.

        Spend the time saved by looking for a new client that is more honorable.

  13. Avatar Loidene says:

    I let them know that I wouldn’t work for fees that were no longer reasonable and customary for the area.  I haven’t accepted fees this low in at least 8 years!  It is a shame, because they haven’t started cutting the return times and I have worked for them for since 2013 though at the same fee as 2013!!

    • Loidene – Clear Caps “clients’ have forgotten what hiring a professional means. Imagine going to your doctor and telling HIM (or HER) that you are charging a $13.00 fluid replenishment charge every time he draws blood; plus a reading or listening consultation charge whenever he explains his findings to you.

      ANY appraiser that puts up with this garbage has an exceptionally low opinion of themselves. It reeks of the late 19th century and early 20th century ‘company store’ approach used by mine owners against their employees.

  14. Avatar Loidene says:

    Until Appraisers Unite, and really take a stand against these ridiculous fees, it will continue. Especially when there are appraiser’s willing to sell their reputation for so little, for such high liability. Thank goodness there are still fair fees available!

  15. Avatar Loidene says:

    I just listened to a pod cast from Voice of Appraisal with Phil Crawford. Voice of Appraisal has a new show! A gift from the ABA!! can be listened to at

    Phil referenced a letter from Sharon Whitaker VP of the ABA speaking about the increased threshold, Raising the Deminimus. The appraisal ordered for the bank is for the bank and not the consumer. Consumers “Should order their own appraisal”. Opens a new market for appraisers. Very important information Ms Whitaker’s letter

  16. By acts of TAF only; appraisals ordered have now become ‘solely for the lender’, and states legal definitions of ‘client’ have been usurped. Every buyer that has ever paid for an appraisal expected to ‘use’ that appraisal-regardless of limitations in the reports that the consumer had no advance knowledge of.

    Traditional state definitions considered the party that paid for a service to be the client regarding that service. We used to advise borrowers “Though you are my client, you are paying for me to provide my impartial and unbiased professional services to the designated lender you have chosen to do business with. Implicit in our relationship is the requirement, knowledge, and expectation that I will provide my services in accordance with USPAP; FNMA Guidelines and any specifically known requirement of the lender related to the value being appraised.” Sometimes those specific requirements directed me not to discuss the value with the client & I’d have to direct them to tell the lender to let me know it was ok, when a question arose.

    It was a much more honest & open way of treating the consumer/borrower

    Because TAF forgot, or chooses to ignore their PRIMARY self described task of protecting the public trust in deference to the dictates of their sponsors (THEIR clients, if you will), we as appraisers have allowed a dishonest definition of who or what a client is to be subverted. In days of old, the lender was never anything more than the intended user along with FNMA.

    ABA is merely propagating that erroneous definition and taking it to a new level. A level that ignores many states mandated fiduciary obligations to the people that pay for the appraisals…regardless of what they are now called. A single party in loan transactions is now arbitrarily redefining legal terms without input or opportunity for input from the other parties to a loan transaction and appraisal.

    THAT is the message consumers should be upset about. THAT is the message and practice they need to be educated on. Educating them to the fundamentals will assure we all have enough work.

    • Avatar don says:

      I used Restricted appraisal as an attempt to protect my self and recognize that all F.M.V.s are not the same.

      For instance one lender might propose a 95% loan against a 2nd and only 5% cash down, with a high interest rate. Another might quote a lower interest rate, but with 20% cash down, and yet another might quote lower interest rates with the borrower submitting additional properties.

      Not all borrowers nor lenders are alike. Not all values are alike, even for the same property.

      The 1004 form includes a description of the terms under which the loan is being made, many times the agents, lenders or mortgage people ignore this.

      I volunteer that my appraisal standard is ??% nor more than 1.5 pts against an 80% 30 year mortgage.

      From time to time I find evidence that the higher values are supported by the looser terms, and I may discuss those items within the report.

      We appraisers seldom know the terms which closed the sale, we do note from differing prices from our knowledge? Most selling-buying agents will tell is asked why basic offers changed in escrow.

      Good appraisal practice takes lots of effort and time which we should charge and be recognized for.


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The Expert Only Gets 10% of Fee

by Jonathan Miller time to read: 2 min