I do believe in the need to standardize measuring, and I have been measuring properties for 37 years, but I don’t think ANSI is the answer (although my opinion is moot). Why on earth can’t our industry formulate our own measuring standard, developed in cooperation with appraisers and other industry leaders? Seems to me one should go to the authorities (boots on the ground) and not use a system primarily designed for builders simply because it is convenient. Heck, they can’t even agree in that industry as the other option FNMA reviewed, in addition to ANSI, called for ceiling heights of 8′. Do you see the ridiculousness of how they went about making their selection? If they had options contrary to one another then why wouldn’t an appraisal industry option not be a legitimate alternative? But I digress, it is all part of their master plan.

Moderator, have any stats on view counts for us? I know when I google matters related to these issues, appraisers blogs gets first page placement. And you can always link people to this site. I gave up on the Appraisers Forum with their login wall and stuffy moderators, that site is truly an echo chamber. This site has a further reach than any other appraisal blog or forum site from what I can tell. Go with the best, post here instead. Website owner pays thousands of dollars a year to keep this site going, it’s no small effort. And 100% of course, but it’s behind a login wall so it’s important to note any disclosure or activism put forth there just won’t reach as far. Had not checked in a while but looks like it still has a lot of activity.
https://www.facebook.com/groups/100RealEstateAppraisers/about/

The only only negative here is we are preaching to the choir. Those who should be reading our comments probably don’t come to this site.

Thank you Jim. Shoot, maybe I should be more careful what I type! JK.

The appraisers blogs is one of the best resources because the moderator does not put any content behind a login wall and allows bot crawlers easy access. I access this site via desktop pc and an internet browser so no limitations with mobiles or facebook either. This site gets top hits on google and a lot of exposure. Kind of bummed I can’t use my real name but with all the amc pushback, just the way it has to be. I’m excited every time a new appraiser or a repeat appraiser decides to write articles for this site or contribute to rich blogging dialogues, much appreciated. Thank you.

Baggins we are reading your comments.

If the purpose is transparency for bolstering consumer protection, it only makes sense for the appraiser to be able to and in fact required to disclose their fee. There should be additional rules the amc must also disclose the total fee for the appraiser to report on too. In our state amc’s are not allowed to force appraisers to sign indemnity agreements and if working with an amc the appraiser must disclose their fee. Wasn’t it NY that required invoices in GSE reports? I recall that happening somewhere because it created technical delays as the secure report portals had to retool some coding as there was a general prohibition on invoice form inclusion which always resulted in automated report rejection.

Also it may be worthy of note that the past 15 years of relentless amc fee and turn time quoting email requests may be considered as commercialized emails and therefore fall under the FCC CAN SPAM act. Appraisers should ask amc’s to stop and if they fail to do so, the appraiser has grounds to file an FCC complaint for violations of spam emails which may carry substantial penalties. Amc’s have been in violation of FCC CAN SPAM rules for well over a decade by not allowing appraisers any opt out or unsubscribe options from their ‘commercialized emails’. Amc’s have spammed the appraiser community more than felonious spammers ever did which landed those spammers in prison. FCC complaints can solve this.

https://www.ftc.gov/business-guidance/resources/can-spam-act-compliance-guide-business
https://www.fcc.gov/general/can-spam
https://drive.google.com/file/d/0B1QWwFfpPTbkUWthNW5kMDhwbmM/view?resourcekey=0-w21KtHAzJPThK150uBupww#list
CO amc rules. Pg 6-17, (b) on indemnity agreements.
https://www.gao.gov/assets/600/592014.txt
Some background on appraisal oversight… The tones are quite different than today. Obviously our industry has been co opted and commandeered by amc’s.
https://www.fdic.gov/sites/default/files/2024-03/fil10082a.pdf
They used to care about things like avm quality, third parties, effective oversight and licensing of people dealing with consumers etc. This above is a good document for all apprentices to read, and appraisers whom may have missed it. A sort of source code or summary for the entire rule sets.
https://www.gao.gov/assets/gao-12-840t.pdf
Effective amc oversight my ass. To this day the hot air the amc’s espoused to regulators was clearly smoke and mirrors. We have been sent millions of what is your fee and turn time requests by these amc companies. They just ignore the rules and pocket the difference. The serious concerns about utilizing amc’s have not been mitigated or even effectively answered and now they would have us all rely on amc sourced ulicensed ‘inspectors’? I don’t think so. No way. No how.

Rejecting amc’s across the board was the smartest business decision I ever made. I could list at least 2 dozen large scale direct assignment lenders, any one or two of them could sustain your entire business, no amc necessary. Just today I got a single from a NB pocket lender, open ended turn time and name your fee, all the while the order is already confirmed to me and me alone. It reminds me of the day when lenders and appraisers worked together well without unnecessary middle management injection or counter productive separation from loan production.

There are rules in lending and amc’s don’t get to just do what they want and buy out certain persons to carve out proprietary market positions to the detriment of consumers and appraisers alike. It comes down to the personal decision of each and every appraiser out there, if enough of us object they have to reconsider these approaches. There is no greater objection than absence.

Good memory with TAVMA. AMC’s never die.. they just change their name. A few years back I worked with our NC State Coalition to try and get a ruling that any AMC order would be required to include the Appraiser Invoice as page 1 for clarification. Hard to get that passed when our Appraisal Board Chairman is an AMC representative. It was proposed, kicked around, tabled and then dumped into File 13 I guess. Another fear right now is that since WE have been so busy the last 2 years it’s been very hard to stay up to date on legislation. AMC lobby has been working harder than ever – and we see the results with this new Cobra Effect. Prayers to us all.

Eric, more lobbyists lobbying against appraisers then there are actual appraisers? I would not be surprised. When the HUD1 form was reformed about 10 years back if I recall correctly, a separate line item disclosure for amc services was on the table. What a monumental mistake it was to allow the amc fee and the licensed appraisers fee to remain improperly co mingled. It was TAVMA at the time rather than REVAA but it makes no difference, they asked, they received. The appraisal industry has been getting decimated ever since. And somehow those bureaucrats now think it’s appraisal racism that is the problem rather than the issues being direct results of their own inability to effectively regulate predatory middle management amc companies. By pushing for higher volume desktop work there will be even fewer appraisers to counter the amc meddling in the future. Amc’s don’t just want a slice, they want the whole thing and to eliminate licensed appraisers entirely, replace everyone with avm and third party services. If you ever wondered where the PIR’s and 2075’s went, they’ve got realty agents flipping those for less than bpo service these days.

I replied to Hagar’s article as follows: “Mr. Hagar misses the point. If a subject property 2nd floor ceiling is 6’6? I can easily measure it and comply with ANSI. The neighborhood comps may or may not have 7 ft ceilings. Our assessors and agents don’t know and there is no other source. I do hope Mr. Hagar will respond and tell me how he does this in his market over the past 20+ years. Personally if I were with Fannie Mae I would have suggested contacting the assessor organizations and use their method.”

Yea, While the AMC fleece the Home Owner for $600+ as they ask then to do their interior inspection. Why is this predatory AMC practice acceptable and the Government not looking into this. How is this going to save time. It most certainly is not going to save the owners any money if the AMC can help it!

All a result of AMC’s making $Millions and using a good chunk of that money to lobby and influence Congress and AARO.net. Our achilles has been cut on both legs. 1. Our Independence is constantly abused by AMC’s. 2. Our squidlike Regulators – no backbone and have become just another arm of REVAA.org. These Lobbyist are at EVERY lender and regulator function buying dinner and drinks for all in Vegas and DC in settings most Appraisers can’t even afford to get a ticket.

If only we could have made more of the past decade and had been able to hire and expand as many of us planned when entering this profession pre hvcc era. Actually that’s 14 years ago now, how time flies. The ongoing violations of the original intention of dodd frank have the potential to be the largest class action in history. If only the CFPB interpretation of the safe harbor rule regarding C&R would not have changed a single word from customary and reasonable to customary or reasonable. aka; cfpb safe harbor rule. Every single day every single instance of an amc paying less than ‘as if an amc was not involved’ should have created a finable offense of $10k/$20k per repeat instance for below customary market fee setting. The amc’s are essentially engaging in racketeering and have made a business model out of that. Cleverly the lobbyists have made original proposed RegZ language virtually inaccessible in historical documents. If anyone can find the $10k/$20k finable language in historical proposed DF documents, please post or share. I have a reference to that in an old Alamode letter but that’s all I can find these days.

These are very important concepts for newer appraisers and regulators looking in from the outside to understand; the variable opportunistic fee raking is prohibited behavior for literally everyone else in the chain of mortgage lending and would be called; unearned fees, junk fees, fee skimming, etc, and is felonious behavior which is specifically defined as prohibited activity in firrea, respa, multiple references in the federal register, among other regulatory guidelines. The irony of reading market update articles on supposed cfpb regulatory activity as linked below when they are the ones whom denied separate line item disclosures and created a safe harbor rule for C&R definition, for the distinctly different service of providing an appraisal report with an appraisal license, vs relaying that report and managing the distribution of requests and payments with improperly co mingled fees, requiring no appraisal license… Imagine the calamity if such a company could be in charge of setting and distributing variable limited fee portions and never returning cost savings to consumers in a co mingled fee scenario for, brokerage fees, realty fees, inspector fees, title fees, notary, home insurance, home repair, etc, etc.

Amc’s enjoy a regulatory loophole which has clearly been detrimental to consumer protection, the viability of the valuation service industry, and mortgage lending efficiency in general. To state it simply; Because amc’s do not need to return cost savings for reduced cost of vendor services to borrowing consumers, they have a constant financial incentive to drive vendor fees down, consumer fees up, and pocket the difference. Quality of reporting, availability of vendors, sustainability of the valuation industry, efficiency, cost, all have suffered as a result. Regulating amc’s as companies had a nill effect because individuals can not be held accountable and there is insufficient check to balance when individual vendors seek regulatory relief against corporations whom sole motivation is to fleece said vendors for substantial portions of their fee. What’s your fee and turn time? aka; violations of the appraiser ‘management rule’ on providing a thing of value to be the preferred selectee. When appraisers discount for amc’s they are essentially bribing their way ahead of the order assignment line. As a result many of us refuse to even quote fees to amc’s on ethical principal. More irony as predatory unethical interests seek to guide the supposed ethical professionals and advise governance on sound regulatory and industry structure. These are violations of the RICO act, if anyone still cares about law and order.

Amc’s expanded at a rapid pace and bragged about business growth to the same businesses they essentially stole the market potential from, the appraiser community. In an effort to capture more and maintain growth these companies portend to speak for our entire community all the while continuing to deny us the potential for growth and apprentice hiring. Sure we can carve out enough for ourselves with a few direct assignment clients but as that potential is roughly one fifth of all mortgage loan volume (as 80% of all orders go through amc middle management fee raking avenues), there are very restrictive market forces which prevent appraisers from being able to take risks that come with expansion and additional overhead. The corporate model in appraisal servicing (and now appraisal management) was never going to work but they continue to beat the dead horse. Appraisers are not much different than the wide array of supportive vendor services for home owners. From inspectors to roof siding window hvac electric, even legal advisement, it is common for individual home owners to benefit more from individual smaller scale vendors.

The application of a commercialized model to the appraisal industry has clearly done more harm than good but they continue to punt for such a model despite it’s obvious failures and shortcomings. Now enter big tech as they digitally map property features and tie that to expansive correlative databases ready for increased exploitation by predatory corporate interests on a worldwide basis. Courtesy of mismo, reso and now ansi which is a global group whom has already carved out special allowances and proprietary market positions through many sectors. It’s all about corning the market these days, using proprietary relationships with governance to get there. A thank you to the author, indeed the devil is in the details.

https://www.lenderlawwatch.com/2022/02/17/cfpb-issues-request-for-information-regarding-junk-fees/
The irony… Consumer protection at all costs, as long as nobody bothers the top lenders at the fed. You can regulate their competition away but they will not be restricted themselves. A process of self asking regulation via a revolving door where excess bureaucracy prohibits market competition and fuels monopolization. They’ll say oh no don’t regulate us we’re here to help, while their same people write the regulation and hand it to politicians for rubber stamp approval. It’s the same thing that’s happening in medicine with the covid nonsense. Corporate government partnerships. They don’t care about efficiency in appraisal but there is money to be made with substantial industry restructuring.
Below attachment: A 10/19/2010 email entitled: JUST IN: “Customary and reasonable” fee regulations, sent via Biggers and alamode. Find this in your historical email for the complete document, and happened to be an alamode subscriber at the time.

The company has yet to update their site Baggins, but rest assured the coach did sell out.
( https://theappraisercoach.libsyn.com/717why-did-dustin-sell-his-appraisal-office )

Seek the truth.

All FNMA had to do to solve ‘appraiser shortage’ was honor the original intention of Dodd Frank RegZ on Appraiser Independence and in doing so basically require amc’s to bill for their ‘management services’ separately. Instead they’ll squeeze the entire industry for more efficiency and leave the fees improperly co mingled. If we were not paying the entire wage burden for the entire amc industry, appraisers could hire more help. Desktops won’t solve anything.

AMEN!

Click the ‘who we are’ tab at the above link. No coach, but still entertaining content. Don’t forget to hover over the images for the reverse graphic flip read. I’m still confident the block will prevail.

Someone should write an article regarding why we chose appraisal. The liberty of time. Not being always tied to a desk. Real independence. Benefits of the knowledge base gained and experience factors with reviewing so many hundreds and hundreds of homes in great detail, often learning valuable insight from home owners and construction persons. Desk jobs are out there though. They can pay well for appraisers if you’re not in the role of an appraiser, pass all the liability, punch in punch out, benefits, retirement, a reliable team to work with.

The real problem is the size of middle management amc’s. We don’t need more efficiency from appraisers, we need more appraisers to handle expanding populace volume. Billions of psiphoned funds to amc’s which would have fueled what could have been 100,000 or more appraisers on the scene today. All FNMA had to do to solve ‘appraiser shortage’ was honor the original intention of Dodd Frank RegZ on Appraiser Independence and in doing so basically require amc’s to bill for their ‘management services’ separately. Instead they’ll they’ll squeeze the entire industry for more efficiency and leave the fees improperly co mingled. If we were not paying the entire wage burden for the entire amc industry, appraisers could hire more help. Desktops won’t solve anything.

Appraisal coach was always a discrace to the profession.

Bill, Thank you for pointing that out.