Thank you Mr Paul. Where did you turn for comprehensive well rounded CE regarding those efforts? Is it possible to perform that service and cleverly just stay out of court? How would you compare the average fees to ML, or do you go straight hourly?

Or keep it simple. “There is no such thing as a safe mortgage loan. You don’t own the home until the final payment is made and you are cleared from all possible clouded title issues.” The truth is there are entirely too many mortgage loans in America. The appraiser is the trusted local professional whom can help people and companies navigate price value relationships in a specific locale. The integrity and viability of the appraisal profession should not be predicated on the production volume of lenders.

Ron, respectfully there are even bigger problems than the AMCs. FAR bigger problems. Like MISMO; TAF always dancing to the lenders tune; or one of their side ventures outside of their Congressional mandate. If standards are inconvenient; no problem just keep rewriting them til they are acceptable to the mortgage bankers.

Appraisals too expensive? No problem, just mandate a systems of transmission that sets the data up to be stolen directly. Look at least one level beyond AMCs…as bad as they are.

Largest class action lawsuit ever? 10k/20k daily fines.

Asking the government to help will result in an even worse anti competitive environment.

Financialize the problem, use lawyers.

I’ve been writing speaking and discussing this for years …but who is going to step up to the plate to eliminate the AMC’s…?

You folks ever get a licensed or certified appraiser on your board yet?

“We’re from the government and we’re here to help.”

Anyone still buying that?

ERC format? Geesh, wish I could have been there to enjoy that. I started 2005-2008 time frames.

My mother still does amc work. Just yesterday she dealt with an mb pressing her for value, instructing the refinance borrower to state the number. Mom fell into the conversation trap and then next day, mb threatening to reassign the order.

I keep telling her, the reason lenders select amc’s is because they want to pressure appraisers, not because they want better separation from loan production. If appraisers would simply get away from amc’s they enjoy better fees, less pressure, and less kickback. Win, win, win.

Lately I just keep on winning, not all the time but enough. I’m nobody special and have no additional accreditation to speak of. However, I did stay at a holiday inn express, and I know how to seek out find and fill out direct lender panel applications. It’s not rocket science.

If amc’s seek to compliment my service, they’ll have to be better at managing lender pressure and advocating for my best business interests than I am. As they have failed to do so; don’t want them, don’t need them, don’t answer for them.

Good point(s). Under the old ERC format, the ERC Company would provide the owner with a list of three approved appraisers. All who had actually demonstrated competency. The owner interviewed us and made their selection; often selecting the higher cost appraiser because they believed they would get a more thorough job by someone they believed to be competent after directly interviewing them. Sometimes they would opt for the lower fee or faster completion time, but not that often. AMCs are supposed to assure competency and report adequacy-but they don’t. No more than they assure any degree of independence from their clients value needs.

Louisiana Real Estate Appraisers Board, In the Matter of Louisiana Real Estate Appraisers Board | FTC

The ftc should recognize the amc is restraining trade by having their fee improperly co mingled with the appraisers fee, which results in restraint of trade and eliminates the ability for the consumer to shop or benefit from cost savings of lower priced providers…

They could force a cost plus requirement and make it all go away overnight.

It’s one thing to provide a lower cost service and be the go to provider since you’re providing more for less cost to consumers. Be the wal mart of the appraisal world, if you’re able.

It’s quite another to have a middle man driving the fees down and pocketing the difference, eliminating the consumers ability to shop for savings or benefit from lower priced vendors, restraining the ability of the vendors to price fairly themselves. That is restraint of trade and application of what equates to junk fees.

The problem is not where the median value lies, the problem is improperly co mingled fees and the financial incentive that creates for amc’s to drive appraisers fees down while simultaneously driving consumer fees up. Now with the additional benefit of also promoting an inferior hybrid service product so they can offer even less and charge even more.

Soliciting directly to lenders matters a lot. Keep my flyer handy and when you get away from amc’s, I’ll be available. This amc solicited me the other day for a keystone reo. “Hey, they were my client. They paid consistent reliable fees. It is the management companies job to present with a reliable consistent upfront fee so what is that fee.” Their response for a multi family base fee I could rely on in the heart of the city; $350. That’s only 350 short of the VA fee for a single family…  Close, no cigar.

What’s your fee and turn time? Response; What’s the consumer fee on this one? I could probably run with that fee if it’s adequate. Easy simple methods.

Every time we look at those we find they’ve consulted with ‘experts’ whom turn out to be amc’s or related somehow. It’s the methodology of data assimilation that really matters. One puts on their tin foil hat very quickly and says, well if they really wanted something without amc’s influence included in the data, why didn’t they simply turn to the public VA fee tables? It actually takes an act of congressional approval to move the VA table fees, they’re reliable long term reference points. Where as these surveys are often much too limited in scope to compare to the credibility of the VA research. VA tables source data from actively working appraisers in every place in the nation, whom work with a very wide variety of lenders and orders of all types. Nothing else compares in terms of validated data integrity.

BB and T just showed the way.

Kind of a chicken and the egg scenario. If appraisers refused to work for substandard fees, then AMCs would have no choice but to raise fees to C&R. We’ve already seen this happen in Washington; Oregon, Colorado and parts of Texas.

If a majority of appraisers are truly too afraid to stand up for themselves, then yes. AMC’s will win, and any discussion of C&R will likely result in other appraisers being selected. No price fixing there at all, is there?

Cost plus is the only solution IF the AMC or AMS model is to be retained.

There is a strong argument for sending the AMC model the same way HVCC went. AMCs have almost universally adopted the mantle of the lenders (read commission compensated loan officer) surrogate violator of appraiser independence and Dodd Frank/Reg.-Z in general

The temptation is to adopt the VA method and rate across the board because it is easier. I could live with that IF that’s the best we can do. I don’t believe it is.

AGA already submitted a C&R fee proposal system that is based on assignment complexity; appraiser skill level and time required. Best of all, it follows U.S. Federal Civil Service appraiser pay guidelines.

Let’s see the FTC challenge that one!

Of course all the efforts to eliminate abuse assumes that’s the objective of the federal and state governments. Treasury Secretary Mnuchin’s recent report to the President on financial reform suggests consumer and public funds protection are very, very low priorities.

We find it odd too.