First the Borrower Fee. Now the Appraiser Compensation in Court
Two lawsuits place Class Valuation’s fee transparency and staff-appraiser compensation practices under federal scrutiny.
Most appraisal disputes examine only one part of the transaction. Two pending lawsuits involving Class Valuation, LLC approach the appraisal process from opposite directions. One asks whether staff appraisers were properly compensated for overtime. The other asks whether a homeowner was properly informed about how an appraisal-related fee was divided.
The cases are legally separate. They involve different plaintiffs, statutes, and courts, and neither has produced a finding that Class Valuation violated the law. Viewed together, however, they raise a question the appraisal profession has asked for years: When a borrower pays one appraisal-related fee, how much reaches the appraiser, how is the appraiser compensated, and how clearly is the remaining charge explained?
For La Rica Golar, those questions moved beyond professional frustration and into federal court. Her lawsuit under the Fair Labor Standards Act seeks relief for herself and other similarly situated Class Valuation staff appraisers.
La Rica Golar’s Lawsuit
Golar v. Class Valuation, LLC was filed March 12, 2026, in the U.S. District Court for the Northern District of Georgia. The complaint seeks to proceed as an FLSA collective action and alleges that Class paid staff appraisers under salary and production or piece-rate arrangements, exercised substantial control over their schedules and assignments, maintained records relating to their work, and failed to pay the overtime compensation allegedly required for hours exceeding 40 in a workweek.
Golar’s employment records describe a full-time Staff Appraiser Supervisor working inside Class’s operations, with employee benefits, reporting responsibilities, supervisory duties, and production-based compensation. Her concerns developed as she compared the time required to complete the work with the way her compensation was calculated.
“The turning point came when I realized that repeated concerns regarding compensation, workload, and the amount of time required to complete assignments were not leading to meaningful change. After exhausting what I believed were reasonable attempts to understand and address those concerns, I concluded that pursuing my rights through the legal system was the only remaining avenue available.”
– La Rica Golar
Golar said she raised compensation and workload concerns during her employment. She understood that Class considered its practices appropriate and consistent with its business model, but she said the discussions produced no meaningful change and left her concerns unresolved.
The Work Does Not End at the Inspection
A residential appraisal is not a single product completed in a fixed amount of time. An assignment may include scheduling, travel, inspection, measuring, photography, public-record research, comparable-sale verification, market analysis, adjustments, report writing, quality-control responses, revisions, meetings, recordkeeping, and – for a supervisor – training or reviewing the work of other appraisers.
“My workweek involved much more than property inspections. A typical week included scheduling appointments, conducting inspections, traveling to and from properties, researching market data, developing valuation analyses, writing appraisal reports, responding to revision requests, addressing quality-control issues, communicating with management and clients, completing administrative tasks, and assisting with appraisal-related supervision responsibilities when required.”
– La Rica Golar
Golar said there were many weeks in which she worked more than 40 hours. She also said production requirements, deadlines, inspections, revisions, and administrative demands affected when and how long she needed to work. In her words, “the practical reality was that meeting expectations often required additional hours beyond a traditional work schedule.”
The Department of Labor explains that, unless an exemption applies, covered employees generally must receive overtime compensation for hours exceeding 40 in a workweek. Earnings may be based on salary, piece rate, commission, or another method, but the overtime analysis generally turns on the employee’s regular rate, hours worked, duties, and any applicable exemption. Golar’s allegations and Class’s potential defenses will have to be tested against those rules and the evidence.
How the Compensation Formula Raised Questions
A January 2023 email exchange supplied by Golar illustrates why the compensation formula became important to her. Golar questioned why a stated 65 percent split did not equal 65 percent of the total client fee. The response explained that the percentage was calculated from an internally designated “appraiser fee” after Class first separated its AMC portion.
In an example involving a $725 client fee, the email designated $507.50 as the appraiser fee. Golar’s 65 percent share was then calculated from that lower amount, producing $329.88. That exchange does not establish an overtime violation, but it shows the difference between the total fee charged for the assignment, the amount Class treated as the appraiser fee, and the amount paid to the employee performing the appraisal work.
“One issue that led me to investigate further was the distinction between the fee charged to the client and the amount attributed to the appraiser. As I reviewed available information, I became concerned that the compensation I was receiving was not based on the total amount paid by the client for appraisal services.”
– La Rica Golar
Golar said the production-based structure created pressure to maintain a high volume of work. “If more work was required to generate the same level of income, that often meant working longer hours,” she explained. “Personally, it affected work-life balance and increased stress because compensation was closely tied to production rather than the total time required to perform all aspects of the job.”
When the Department of Labor Did Not Investigate
Before filing suit, Golar took her complaint to the U.S. Department of Labor’s Wage and Hour Division. According to a February 4, 2026 letter she supplied for review, the agency said the complaint met the requirements of a valid complaint but that limited resources prevented an investigation. The letter did not decide the merits and preserved her ability to pursue a private action. She filed the federal case the following month.
“The response reinforced my belief that I would need to pursue the matter independently if I wanted the issues examined further. While I understood the resource limitations described to me, I also believed the concerns deserved a formal review.”
– La Rica Golar
The Two Cases at a Glance
Golar case: Federal FLSA collective-action complaint filed March 12, 2026. It alleges unpaid overtime affecting qualifying current and former Class Valuation staff appraisers.
Bernholtz case: Proposed consumer class action involving CrossCountry Mortgage and Class Valuation, removed to the U.S. District Court for the Southern District of Florida on July 17, 2026. It alleges that a $700 appraisal charge included an inadequately disclosed management component.
Important distinction: One case concerns employee overtime; the other concerns consumer fee disclosure. A ruling in one case will not automatically determine the other.
Status as of July 28, 2026: Both cases remain pending. The courts have not decided the merits, and collective or class treatment is not guaranteed.
The Homeowner Case Approaches the Fee From the Other Direction
Bernholtz v. CrossCountry Mortgage, LLC and Class Valuation, LLC begins with the total amount paid by the borrower. Plaintiff Clayton Bernholtz alleges that he paid a $700 appraisal-related fee in connection with his mortgage transaction and was not adequately informed that the charge included an AMC management component retained by Class Valuation. The proposed Florida class asserts claims including alleged unfair or deceptive practices, unjust enrichment, and breach of contract.
The defendants may dispute those allegations and argue that the charge was lawfully disclosed, that AMC services provided value, and that no separate line item was required. The case was removed to federal court on July 17, 2026. As with Golar’s case, the complaint begins the litigation; it does not decide it.
Where the Two Lawsuits Meet – and Where They Do Not
The factual overlap is straightforward. The homeowner case examines the money entering the appraisal transaction and what the borrower was told about it. Golar’s records examine how one staff appraiser’s compensation was calculated after Class separated its AMC portion from the total client fee.
Together, the cases place two parts of the same business model under scrutiny: fee transparency on the consumer side and compensation compliance on the production side. The combined question is not whether an AMC may charge for legitimate services. It is whether the division of the fee is clearly explained and whether the staff appraisers completing the professional work are compensated lawfully for their time.
“If the borrower pays more than the appraiser receives, the difference should be understandable, connected to actual services, and supported by a lawful compensation system.”
– Kenneth J. Mullinix
What the Cases Mean for Class Valuation and the Industry
For Class Valuation, the immediate concern is not simply that two complaints exist. It is that two courts may examine different records from the same appraisal delivery system. The Golar litigation may focus on time records, workload expectations, assignment control, pay formulas, and overtime calculations. The Bernholtz litigation may focus on invoices, fee allocation, consumer disclosures, contracts, and the services associated with the AMC’s retained portion.
If either court permits the claims to proceed collectively or on a class basis, the dispute moves beyond one employee or one homeowner. If Class defeats the claims, the decisions could reinforce existing practices, depending on the grounds for the rulings. Either way, the lawsuits create pressure for a careful review of how hours are recorded, how production compensation is explained, and how appraisal-related charges are presented to consumers.
The larger industry issue is appraisal quality. Credible valuation requires time to verify data, select appropriate comparables, analyze market behavior, explain adjustments, and respond thoughtfully to legitimate review questions. Compensation systems that reward volume without accurately accounting for the hours involved can contribute to burnout, turnover, and pressure to complete complex assignments too quickly. The lawsuits do not establish that Class appraisal quality was compromised, but the profession should not pretend that workload, compensation, and quality are unrelated.
Independent appraisers also have reason to pay attention, even though Golar’s lawsuit concerns employees. The Bernholtz case addresses the gap between what a borrower pays and what reaches the appraiser. Greater disclosure could make AMC margins more visible and encourage lenders to compete on the full cost of appraisal management rather than presenting the professional fee and management fee as one indistinguishable charge.
“My hope is that the lawsuit promotes greater transparency, accountability, and fairness. I believe appraisers play a critical role in the mortgage and real estate industries, and they deserve compensation systems that are understandable, equitable, and compliant with applicable laws. Beyond my own situation, I hope this case encourages constructive discussion about how staff appraisers are compensated, how workload expectations are established, and how professional valuation services are valued within the industry.”
– La Rica Golar
How Current and Former Class Staff Appraisers Can Learn More
La Rica Golar’s lawsuit seeks to proceed as an FLSA collective action on behalf of current and former Class Valuation staff appraisers who may have worked more than 40 hours in a workweek without receiving legally required overtime compensation. Staff appraisers who experienced similar workload, compensation, or overtime concerns are not automatically included, but they may contact Hall & Lampros to ask whether they qualify and what steps may be required to opt into the case. Eligibility depends on each appraiser’s employment dates, duties, hours worked, compensation structure, and other individual facts.
Conclusion
La Rica Golar’s lawsuit asks whether a national AMC’s staff-appraiser compensation system properly accounted for the hours required to produce professional valuation work. The Bernholtz lawsuit asks a different but related question: whether a borrower understood how an appraisal-related fee was divided.
The legal outcomes remain uncertain. The plaintiffs must prove their claims, the defendants are entitled to present their defenses, and collective or class treatment is not guaranteed. But the cases have already placed longstanding industry concerns into the public record.
For the appraisal profession, the message is direct. Borrowers should understand where the appraisal payment goes. Appraisers should understand how their compensation is calculated. Employees should be paid lawfully for compensable hours. Transparency will not resolve every dispute, but it makes important compensation decisions far more difficult to hide inside a single fee or percentage.
Case Information and Public Links
Golar case and eligibility information: Hall & Lampros – Class Valuation Staff Appraiser Lawsuit
Golar federal docket: Golar v. Class Valuation, LLC, No. 1:26-cv-01377
Related homeowner case: Bernholtz v. CrossCountry Mortgage, LLC et al., No. 0:26-cv-61978
Related news coverage: National Mortgage News – CrossCountry Mortgage sued over inflated appraisal fees
FLSA overtime guidance: U.S. Department of Labor – Fact Sheet #23
Attorneys for La Rica Golar: Hall & Lampros, LLP; Christopher B. Hall and Gordon Van Remmen; (404) 876-8100; chall@hallandlampros.com; gordon@hallandlampros.com.
Baggins, thank you for taking the time to provide such a detailed response. You have expanded this discussion in an important direction. La Rica Golar’s lawsuit concerns compensation and overtime, but the larger issue is how much control an AMC exercises over the appraiser performing the work.
The employee-versus-independent-contractor debate is as old as organized labor. A company cannot necessarily avoid its responsibilities simply by calling someone an “independent contractor.” If a company decides where the worker goes, assigns the work, sets deadlines and working hours, requires office attendance, controls compensation, supervises performance, provides continuing instructions, and can reduce or terminate the worker’s future opportunities, those facts can point strongly toward an employer-employee relationship.
The legal determination depends on the complete relationship—not one factor or the label placed in a contract. The Department of Labor examines whether the worker is economically dependent on the company or is genuinely operating an independent business. The IRS similarly considers how much control the company retains over the details of how the work is performed. [Department of Labor guidance](https://www.dol.gov/agencies/whd/fact-sheets/13-flsa-employment-relationship) and [IRS behavioral-control guidance](https://www.irs.gov/businesses/small-businesses-self-employed/behavioral-control).
We have seen the same debate involving truck drivers, ride-share drivers, construction workers, delivery drivers, and many other occupations. The company wants the control and consistency of an employee while sometimes attempting to avoid the corresponding wage, overtime, tax, benefit, and record-keeping obligations. A company should not be able to exercise employer-level control and then claim that the worker is completely independent when compensation becomes an issue.
La Rica was already working as a staff appraiser and receiving employee benefits, so her lawsuit is not primarily about whether she was an employee. The central question is whether Class Valuation’s compensation system properly accounted for all compensable hours and legally required overtime. However, the degree of control alleged over assignments, schedules, production, supervision, revisions, and performance remains highly relevant.
In my opinion, the allegations and supporting records raise a serious question about whether Class crossed the legal line in how its staff-appraiser compensation system operated. That is now for the court and the evidence to determine. If the case proceeds collectively and the allegations are proven, it could become a game changer—not only for current and former Class appraisers, but for staff-appraiser compensation models throughout the AMC industry.
I also agree that the assignment platforms deserve far more scrutiny. Internal platform records could show:
* Who approved, downgraded, suspended, or disabled an appraiser;
* Whether an appraiser’s rating changed after an ROV or an appraisal that did not support a transaction;
* How fee levels affected appraiser selection;
* Whether performance information was shared among lenders and AMCs;
* Whether appraisers received fewer assignments after reporting unsupported values; and
* Whether work was actually distributed independently or controlled through hidden rankings.
Those records could distinguish legitimate quality control from retaliation, coercion, or undisclosed blacklisting. The industry should not assume misconduct without evidence, but appraisers should not be expected to accept invisible scoring and removal systems without transparency either.
I would make one distinction concerning ROVs. A legitimate request to correct an error or consider relevant additional information is not automatically coercion. It becomes a valuation-independence concern when payment, continued employment, future assignments, rankings, or retention are tied to whether the appraiser reaches a desired value. Federal valuation-independence rules prohibit direct and indirect attempts to replace an appraiser’s independent judgment with a predetermined result. [CFPB Regulation Z, §1026.42](https://www.consumerfinance.gov/rules-policy/regulations/1026/42/).
That is why La Rica’s case matters. Compensation, workload, assignment control, performance grading, ROV pressure, and appraisal independence cannot always be separated into individual boxes. When the same company controls the assignments, production expectations, compensation formula, reviews, rankings, and continued employment, the entire system deserves examination.
Current and former Class staff appraisers with similar overtime or compensation concerns should preserve their employment agreements, pay records, time records, assignment histories, production reports, emails, ROV records, performance evaluations, and communications with management. They should contact the attorneys handling the case to determine whether they may qualify rather than assume they are automatically included.
I am also willing to listen to and assist other appraisers at no charge when I reasonably can. I am not a lawyer and cannot provide legal advice or representation, but I may be able to help an appraiser organize the facts, identify important documents, locate public information, and formulate the right questions to take to qualified counsel.
Thank you again, Baggins. The profession needs this discussion, but it also needs documents, platform records, witnesses, and verifiable evidence. That is how longstanding industry concerns can move from private complaints into meaningful accountability.
(licensed appraiser employee) I maintain USPAP compliance and make independent decisions. You can not tell me what to do or force me to provide positive client outcomes. You can deal with that.
(Appraisal management company staff director steps into the room) Um, we’re going to have a special conversation in my office right now about your work performance.
(lender’s conversation with the appraisal management company staff director) You’d better get your appraisers in line and stop killing so many deals or we’ll replace everyone and you’re all fired by the end of the week.
AIR compliance regulatory guidelines, legally described as ‘Valuation Independence.’
https://www.consumerfinance.gov/rules-policy/regulations/1026/42/
Every day violations and contradictory guidelines of this principal which occur with both direct assignment lenders and appraisal management companies: (related links provided as necessary)
(1) Coercion. In connection with a covered transaction, no covered person shall or shall attempt to directly or indirectly cause the value assigned to the consumer’s principal dwelling to be based on any factor other than the independent judgment of a person that prepares valuations, through coercion, extortion, inducement, bribery, or intimidation of, compensation or instruction to, or collusion with a person that prepares valuations or performs valuation management functions.
ROV, reconsideration of value guidelines.
https://singlefamily.fanniemae.com/initiative-updates/reconsideration-value-rov
NOTE: Seems kind of odd. If an appraiser performs acceptable work and was good enough to make it onto the lender or amc’s approved appraiser panel in the first place, why would such a policy be necessary? The boss was not happy with your value opinion, you are now required to reconsider or you don’t get paid. One may also refer to this as a policy which encourages rather than discourages coercion. Contradictions.
Examples of actions that violate paragraph (c)(1) include: (coercion)
(A) Seeking to influence a person that prepares a valuation to report a minimum or maximum value for the consumer’s principal dwelling;
NOTE: ROV policies.
(B) Withholding or threatening to withhold timely payment to a person that prepares a valuation or performs valuation management functions because the person does not value the consumer’s principal dwelling at or above a certain amount;
NOTE: ROV policies.
(C) Implying to a person that prepares valuations that current or future retention of the person depends on the amount at which the person estimates the value of the consumer’s principal dwelling;
NOTE: AMC performance grading policies which often score appraisers based on their ability to avoid having ROV’s issued, and penalizes them with reduced workload or deranking on tiered appraiser status if they have too many rov’s.
(D) Excluding a person that prepares a valuation from consideration for future engagement because the person reports a value for the consumer’s principal dwelling that does not meet or exceed a predetermined threshold; and
NOTE: Killing the deal, the reason why ROV’s are issued. Appraiser performance rating. This also manifests in the form of appraisers often reviewing MLS market data for purchase order appraisal requests, (aka comp searching prior to order acceptance) and not accepting orders., which also causes bad grading and delisting for not accepting enough orders.
(E) Conditioning the compensation paid to a person that prepares a valuation on consummation of the covered transaction.
Note: The process is the penalty. ROV policies consistently penalize appraisers whom do not make deals work. These are functions built into the assignment software platforms and are often automated in nature vis the lenders choices for how their assignment software platform behaves. Image attachment from SCOPE (corelogic) systems. Currently active appraisers for a major lender that has 22 client branches, 8,409 active appraisers on their panel, 6 amc’s they also send work through outside their direct assignment systems (Maria pay attention here, this is what I posted about above), total asc license tracking which is rather irrelevant as this dates back to the early days but otherwise known as the appraiser index much like a phone book for all appraisers ever available, then 2,349 disabled appraisers category. Examine the ratios of approved appraisers vs disapproved. 8409 vs 2349. That is the secret blacklisting and this lender was actually really good at not doing that. Other lenders have far higher ratios.
One click from anyone in the network, one transfer of associated disproval status from any of the amc’s they’re also working with on that same platform, that’s all it takes to be effectively removed from active assignment. And finally 249 pending appraiser applicants. The stand by’s whom have had their applications approved, but are not yet set to the active panel. They get their chance in the ring whenever the next guy gets blacklisted. Seeing how this works yet from the management side? All anyone needs to do in order to have all the data on this behavior is subpoena the assignment software platform records or somehow pry those out in discovery process. Or simply call and speak to the csr’s. One can get a client side login at any of these software companies and build your own appraiser panel. You’ll see remarkable capability where you can search by appraiser fee (in violation of appraiser selection guidelines), observe shared star rankings (your performance grading with one client is not held in isolation to just that client), and observe other volume coverage and performance metrics that make mass onboarding easy, and constant deselection even easier. The appraiser never gets to know. The appraisal software assignment platforms are built in a way which encourages rule breaking. You could not get the system to run true rotational assignment if you wanted to. The people developing and maintaining the appraisal assignment software platforms have almost no understanding of what the regulatory guidelines are for lenders or appraisers. They just produce the tech as the lenders and amc’s ask of them.
(ii) Falsification or alteration. In connection with a covered transaction, no covered person shall falsify and no covered person other than a person that prepares valuations shall materially alter a valuation. An alteration is material for purposes of this paragraph (c)(2)(ii) if it is likely to significantly affect the value assigned to the consumer’s principal dwelling.
https://singlefamily.fanniemae.com/property-valuation/value-acceptance
Value acceptance is Fannie Mae’s offer to accept the lender-submitted property value in Desktop Underwriter® (DU®) with no appraisal requirement for eligible transactions. The value submitted must be based on the contract price for a purchase transaction or the lender’s or borrower’s estimate of property value for a refinance transaction.
NOTE: Dear state of Maryland; Drop Dead. No conflicts of interest here. The commissioned based lenders being able to auto pass deals via their internally controlled black box avm systems with absolutely no external oversight or auditing requirements. You may recall the passing of ‘Quality control standards for Automated Valuation Models’ in late 2024, as published in the federal registry. Lenders are required on a bi annual basis to fill out a two page voluntary compliance form which certifies that their internally controlled non audited, proprietary valuation technology is just as good as an actual independent appraisal service. They would never falsify value and the public can never know about how their proprietary avm technology works.
The best part about appraisal modernization is instead of one uniform standard for valuation service that everyone could rely on, providing the bedrock stability of the housing market, instead there are now ten different valuation standards, pick what works best for you, your deal at hand. It’s only a coincidence that treasury notices of mortgage delinquency and pending foreclosure are approaching 2008 levels or whenever they peaked prior. Don’t worry, that’s where loan restructuring kicks in and if things go south, pennies on the dollar firesale pricing via ‘note sales’ and ‘debt sales’ happens via FNMA’s Whole Loan program, and HUD’s bulk portfolio debt sales directly to institutional investors. We can’t have a foreclosure crisis, if there are no foreclosures in the MLS system.
(i) In general. No person preparing a valuation or performing valuation management functions for a covered transaction may have a direct or indirect interest, financial or otherwise, in the property or transaction for which the valuation is or will be performed.
NOTE: Possibly contradictory guidance point considering the AVM final rule? The lender is an interested party to the transaction. Yet they’ve implemented a work around and now issue the valuations. Sidestepping the intent of regulation.
(ii) The person preparing a valuation or performing valuation management functions reports to a person who is not part of the creditor’s loan production function, as defined in paragraph (d)(5)(i) of this section, and whose compensation is not based on the closing of the transaction to which the valuation relates; and
NOTE: We keep the tech guys in the basement. They provide valuations for us, their lender employer, well, from somewhere else.
(iii) No employee, officer or director in the creditor’s loan production function, as defined in paragraph (d)(5)(i) of this section, is directly or indirectly involved in selecting, retaining, recommending or influencing the selection of the person to prepare a valuation or perform valuation management functions, or to be included in or excluded from a list of approved persons who prepare valuations or perform valuation management functions.
NOTE: There is no such thing as a rotational standard anywhere outside of the VA platform. Prior to amc’s a rotational order assignment standard used to be the gold standard of the entire industry. Again, performance ranking as cover for exclusion from future working opportunity, blacklisting. ARCC has these companies dead to rights with whistleblower disclosure. Every amc employee in the world knows it’s happening, that’s their job.
(i) Loan production function. The term “loan production function” means an employee, officer, director, department, division, or other unit of a creditor with responsibility for generating covered transactions, approving covered transactions, or both.
NOTE: Is that possibly also a function of appraisal management companies? Inquiring minds want to know.
(1) Requirement to provide customary and reasonable compensation to fee appraisers. In any covered transaction, the creditor and its agents shall compensate a fee appraiser for performing appraisal services at a rate that is customary and reasonable for comparable appraisal services performed in the geographic market of the property being appraised. For purposes of paragraph (f) of this section, “agents” of the creditor do not include any fee appraiser as defined in paragraph (f)(4)(i) of this section.
NOTE: VA does serious surveys for C&R market rates. They’re published online for the world to see. Most appraisers simply can never find a mortgage lending client or amc company that pays VA rate or higher. VA approved lenders have all the internal statistical data which confirms; When they use amc’s they pay less, pass appraisal program cost back to appraisers, and have far more ability to pressure appraisers which leads to higher loan closing rates. That’s why they use amc’s.
https://www.benefits.va.gov/HOMELOANS/appraiser_fee_schedule.asp
(ii) The creditor and its agents do not engage in any anticompetitive acts in violation of state or Federal law that affect the compensation paid to fee appraisers, including:
NOTE: Sherman Antitrust Act, Restriction of trade, Wire fraud, collusion and coordination via REVVA amc trade group. The functions built into the appraisal assignment platforms themselves.
(A) Entering into any contracts or engaging in any conspiracies to restrain trade through methods such as price fixing or market allocation, as prohibited under section 1 of the Sherman Antitrust Act, 15 U.S.C. 1, or any other relevant antitrust laws; or
NOTE: Market allocation. Perhaps you’ve heard of appraiser performance grading and tiered appraiser ranking? Where companies ‘allocate’ disproportionate assignment volume to the appraisers with best ‘stats’?
(B) Engaging in any acts of monopolization such as restricting any person from entering the relevant geographic market or causing any person to leave the relevant geographic market, as prohibited under section 2 of the Sherman Antitrust Act, 15 U.S.C. 2, or any other relevant antitrust laws.
NOTE: The 50k small business appraisers whom are now gone. The other tens of thousands that left the mortgage lending segment of the market. The thousands more that are going to leave with 3.6 uad forms? The glaringly obvious differences between traditional tried and true appraisal practice using general purpose forms vs new 3.6 forms.
The definition of Fee Appraiser. Now you know why amc’s race to consolidate. So they can get the exemptions.
(ii) Appraisal services. The term “appraisal services” means the services required to perform an appraisal, including defining the scope of work, inspecting the property, reviewing necessary and appropriate public and private data sources (for example, multiple listing services, tax assessment records and public land records), developing and rendering an opinion of value, and preparing and submitting the appraisal report.
NOTE: I guess it’s now o.k. for non licensed property data collectors to provide legally defined appraisal services without a license. Appraisal services include property inspection. It’s right there in black and white. Practicing without a license. Encouraged by the licensed amc companies. ‘That’s a violation!’
Nobody cares about the actual rules anyways. Who even bothers to read this stuff? Total waste of time.
(KEN) Please share your thoughts:
* What changes would make the system fairer for appraisers and borrowers?
Oh Ken that’s too easy come on. We appreciate your efforts. Rather remarkable how groundbreaking so much of this is. Great job. A functional form of appraisal modernization was proposed in the year 2013.
Missing the IVPI Proposal yet?
https://www.workingre.com/wp-content/uploads/2013/08/IVPI-Proposalfinal.pdf
https://www.workingre.com/wp-content/uploads/2013/08/IVPI-ENDORSEMENT.pdf
Although they’ve always tried to treat us as both employees and as independent contractors, as it suited their purposes of the moment, I’ve really never understood how anyone could ever be an actual appraiser who was an employee and or why such is even allowed by the controlling entities. Saying that one is an appraiser and an employee at the same time is simply BS.
**Thank You—and an Invitation to Appraisers Nationwide**
I want to thank **AppraisersBlogs** and **Working RE Magazine** for giving appraisers a national forum where difficult industry issues can be examined openly. I also want to thank **La Rica Golar** for trusting me with her experience and answering difficult questions about her workload, compensation, and decision to file a federal lawsuit against Class Valuation.
The newly published article, **“First the Borrower Fee. Now the Appraiser Paycheck,”** examines two separate lawsuits involving Class Valuation. One concerns alleged unpaid overtime for staff appraisers. The other concerns the alleged lack of transparency surrounding the division of an appraisal-related fee paid by a borrower.
The lawsuits remain pending, and the allegations have not been decided by the courts. Nevertheless, they place two longstanding industry concerns into the public record at the same time: what borrowers are charged and how the appraisers performing the work are compensated.
I especially want to thank appraisers across the country who take the time to read and discuss this article. Your feedback is needed. Staff appraisers, independent appraisers, former AMC employees, and other valuation professionals may see these issues differently, and their experiences can help the profession better understand how workload, compensation, fee transparency, and appraisal quality are connected.
Please share your thoughts:
* Have production expectations made it difficult to complete assignments within a normal workweek?
* Were compensation formulas clearly explained?
* Did you understand how the borrower’s total fee was divided?
* Do current disclosure practices provide enough transparency?
* What changes would make the system fairer for appraisers and borrowers?
I also want appraisers nationwide to know that I am willing to help, without charge, when I reasonably can. If you are facing an appraisal-related employment, AMC, regulatory, compensation, or professional concern, I am available to listen, discuss your experience, help organize the facts and documents, and point you toward potentially useful public information or professional resources.
I am an appraiser—not a lawyer—and I cannot provide legal advice, represent anyone, determine whether a legal claim exists, or replace qualified legal counsel. Communications with me are not protected by attorney-client privilege. Anyone facing legal deadlines, possible retaliation, unpaid wages, licensing action, or another serious legal issue should promptly consult a licensed attorney. Still, after more than 30 years in this profession, I may be able to help another appraiser better understand the issue, organize the history, and identify sensible questions to ask.
Current or former Class Valuation staff appraisers who believe they experienced similar overtime or compensation issues should review the public case information and contact the attorneys handling La Rica’s lawsuit to determine whether they may qualify. They should avoid posting confidential employment records or privileged legal communications publicly.
This article is not intended to decide either lawsuit. Its purpose is to encourage transparency, accountability, and an honest national discussion about how professional appraisal services are managed, priced, and compensated.
Thank you again to AppraisersBlogs, Working RE Magazine, La Rica Golar, and every appraiser who reads, comments, shares their experience, or helps another professional find their voice.
**Kenneth J. Mullinix**
California Certified Residential Appraiser
FHA & VA Appraiser
Real Estate Consultant
Appraisal-Industry Contributor
More Than 30 Years of Residential Valuation Experience
transparency, accountability, and an honest national discussion….lol. That can’t happen with AMCs that are the creation of lenders and lender interest groups.
if a lender needs to use a AMC then they should be paying that fee – and should be run like the VA – it’s $700 with a 7-10 BUSINESS day turn started the day after it was assigned to you – as this is my base fee – used to be a slave to the AMC – just said this is BS they don’t care – got a few lawyers and on the states to do foreclosures drive-by – and they pay more then these MIDDLE MAN – the fee for the lender to use the AMC should be paid by them – plain and simple – stick to your guns – this article shows the basic fee is $700 – these AMCs want to add there technology fees and deliver fees & take it out of the little ass fee – nope – if everyone just said NOPE and stopped doing work for them and see how they fall – but if VA changes to the new form i’m out unless there is a fee update for it. but i’ll do drive-bys for $600 plus doing and oath $125 plus taxes
and i keep getting requests for $325 full appraisal – some BS fee and given 2 days to do – so if 16 hours – they can pound sand
“Golar said there were many weeks in which she worked more than 40 hours. She also said production requirements, deadlines, inspections, revisions, and administrative demands affected when and how long she needed to work. In her words, “the practical reality was that meeting expectations often required additional hours beyond a traditional work schedule.” ”
Poor thang. Smirk.
All I know is when the 3.6 becomes mandatory for VA appraisals, that is when I walk away. No question. No doubt. I’m not going to complete the 3.6 forms. I’ve taken the classes. Looked at the forms. I did not work the last 20+ years only to end up being a “form filler”.
AMCs argue that their work has value. Yah, 95% less value than that of an appraiser. Their work doesn’t decide if a mortgage is made. Take out the appraiser and where does that leave them. Out of business. We need more respect from all stakeholders and fairer fees from AMC’s… or get rid of them. Also, did you ever think that posting here could be read by any AMC and affect your relationship with them?
Get rid of them……….is the ultimate solution. Lower cost to consumers and equitable pay to appraisers.
Sure, the amc structure is all about taking advantage of appraisers. You fall in line for their benefit or they can and will push the appraisers around and out. This is a purposeful approach to sift away real independents as well as those whom would apply a higher ethical standard to their every day business dealings.
You’re touching on an important point without quite having a full understanding of where the other appraisers promoting these positions are at. We can’t boycott amc companies twice. Who cares what they know about us. We don’t work with them anyways.
Wrote this piece three and a half years ago. How time flies. This was a really great piece. We could see the writing on the wall then as clearly as now. Appraisal trade groups remain on the sidelines unwilling or incapable of advocating on behalf of mortgage lending focused appraisers.
Amc’s and the tech companies they work with have also taken control of appraisal licensing qualification guidelines as they intend to expand their influence through more independent markets, turning them into franchise models under their control, as well as having injected their ever expanding wish list of additional developmental allowances into the uspap uniform standards of professional appraisal practice. Activity which was clearly prohibited a decade ago is now condoned and promoted today. Unlicensed inspection runners for everyone! Who needs to take licensing seriously anyways. Have you ever held a working position where you worked around anything to do with lending, real estate, or finances? Congratulations, you’re an appraiser now.
https://appraisersblogs.com/vote-with-your-wallet-we-cannot-boycott-amc-industry-twice
Misidentifying appraisers, not paying for work performed, overtime, etc. is not new. See below for an article from this site dated Sept 3rd, 2015.
https://appraisersblogs.com/appraisal/appraisers-landmark-36m-settlement-with-bofa/
See below for my comments at the time.
(1) When is the last time a lender client and or AMC called you to ask your opinion on how new regulations are going to affect your business (appraising)? With in essence nonnegotiable
appraisal fees set to take place with TRID implementation, have they offered a solution to address complexity fees discovered after the appraisal fee has been locked in? Are they offering to raise the fees to offset the times complexity fees can’t be charged? Has anyone been contacted from a lender saying they are raising FHA appraisal fees based on the new regulations? The answer is of course NO. As it relates to BOA and Landsafe, when they pay a split fee for production and a higher percentage for the more work you do, are they asking how many hours it takes to make this happen? Does it matter to them that they pay you as an employee (staff appraiser) but to produce to a high standard of work you may work 12 hour days to make it happen? With the average settlement to each staff appraiser estimated to be $64,000, BOA will NOW say it matters. Good news to CA appraisers as the state has a longer statute of limitations, thus the portion of the payout will be higher than most states.
(2) Update. My original appraiser trainer who has been a staff appraiser with Landsafe since 2008, just received an update as to the minimum settlement they will receive. As a high-volume producer in the state of CA the minimum payment amount will be $139,000 and could be much higher depending on lawyer costs. Where is the respect when it comes to treating the staff and independent appraisers fairly?
Seek the truth.
GD, took long enough. All any of the appraisers on the inside of these systems needed to do was highlight the deceptive and abusive practices. We’ll remain mystified only one appraiser has taken these steps with only one amc company. These are industry wide practices.
Who will have the courage to go next and pursue a similar pattern of validation through the government agencies, then eventual filing in court for far more common provable issues which there is far more documentation not held behind a veil of corporate secrecy?
IRS definitions of being an employee vs independent contractor. The rules are clear that if companies push 1099’s around like employees, additional compensation is due. Read up. File. Make a difference.
I personally think it’s obvious 1099’s should be classified as remote employees under these rules and descriptions. This could potentially apply to many direct assignment situations working with lenders and no amc’s involved as well. The controls are built into their assignment platforms. Especially now with the new 3.6 and these demands to also control what technology and methodology appraisers use, the removal of previous flexibility and open ended approaches. The hubris thinking appraisers would remain powerless to resist their pressure campaigns and they’d shut tens of thousand more independent businesses down, compromise the financial stability of housing markets through the entire country, impose never ending debt traps on citizens and non citizens alike without any consequence.
What they’re hoping for is that independent 1099 appraisers don’t also fill out the IRS forms then contact lawyers about the definition of 1099 vs employee. Whatever was settled regarding this issue in the past happened before amc’s claimed market dominance. Before appraisers were subjected to never ending restriction of trade and practice limitations, blacklisting and removal from active rotation if we did not capitulate to the ever increasing coercive pressure amc’s, lenders, and the GSE’s themselves piled onto the process. Appraisers are no longer in charge of a great many things that used to define us as 1099’s; Time, expense, income, scheduling, behavioral control, other financial controls, development methods, right to refuse without penalization, etc, etc, etc. Maybe you’ve heard of this thing called appraiser performance grading and tiered panel ranking?
https://www.irs.gov/businesses/small-businesses-self-employed/independent-contractor-self-employed-or-employee
https://www.irs.gov/newsroom/worker-classification-101-employee-or-independent-contractor
https://www.irs.gov/taxtopics/tc762
‘If you want the IRS to determine if a specific individual is an independent contractor or an employee, file form SS-8’
https://www.irs.gov/forms-pubs/about-form-ss-8
Rut Roh!!!
Let me get this straight. We finally see what the staff appraisers cut really is and apparently we are supposed to act impressed that it is a solid 45%. Class has been out there tossing around that 65% number, while in reality the staff cut is 45% and independent appraisers are sitting at 35-38%. Meanwhile Class keeps 55-65% without blinking. This is the kind of corrupt conning garbage that makes appraisers hate AMCs and why nobody trusts a single thing they say.
Good catch. She may have been getting a bigger slice because she was a Staff Appraiser Supervisor, so that 45% might actually be the higher end of their staff scale. Which means regular staff appraisers could be getting something closer to what independent appraisers get or even less. Can you imagine making $329.88 per report in 2026 plus all the extra work they pile on? That was our base fee in the 90s.
Exactly. Why would any reasonable appraiser thinking logically, work under these conditions? It makes no business sense and never has made sense. Working for AMC’s is equivalent to professional slavery.
Not to offend anyone but if it were truly a profession appraisers would have organized decades ago and shut down AMCs on day one. Professionals protect their profession…do they not?
Yup!
Well Retired you’re right again. But also there is variety evidence to the contrary. Kind of cuts both directions. Fifty thousand small businesses left because of the intimidation and constant pressure these companies applied. Over the next fifteen or so years another few tens of thousand appraisers left GSE work all together. Nobody can know for sure but we can speculate a hundred thousand new small business appraiser licensees never came to be. Fifteen billion dollars or more of redirected work amc’s lifted out of the work supply along with the fee skimming would have gone a long way in this industry. Amc’s grew to specialize in managing small business appraisers right out of the process, stifling and reversing all prior small business growth.
I’m hoping to cover that in an article next week. Been working on this for a while now. Too much going on in the summer. Garden is popping. Steady producing a bag of cucumbers and tomatoes, assorted peppers every week. I’m in the garage again quite often fixing vehicles which has been really great and rewarding. Why didn’t I buy the better tools before, they make the jobs much easier. All I really want to do is get back up to the rocky mountain park and go fishing again. Somehow even with one singular client, no website, hardly any web presence, and dialing this in for the past five years or longer, I’m still getting work orders. Another two right now. Well, will get to finalizing another article soon, almost done.
The bright side is that finally, someone actually did something. We’re seeing an uptick in people whom have had enough, every few months another new story or notable event. That’s great news.
You’re right, and honestly that’s been one of the biggest problems in this field. Appraisers never had a unified front or any real structure to push back with. We’ve always been a bunch of solo operators scattered across the country, each running our own shop, dealing with our own clients, and trying to survive whatever the lenders threw at us. AMCs walked right into that vacuum. By the time people realized how bad the model was, the lenders had already baked it into their workflow and the Appraisal Institute wasn’t exactly out there swinging on our behalf. If we had organized early, AMCs would have been stopped before they ever got traction, but the profession was never set up like that. We’re still paying for it.
I’m putting together a stand alone article that deals with many of the issues you mention. Hopefully can put that together by the start of next week. Stay tuned.
Where do I sign up? They bought the prior company I worked for and did the same thing to me.
I was “fired” though was independent and not staff appraiser, because I was not willing to reduce the quailty… blacklisted
Shitty companies reflecting the lack of ethics by the management or owners.
AMC’s are leaching off our profession and stealing money from us
But you still have the clown appraiser doing the work for them. Why on God’s earth would you take such a massive pay cut to work full-time with an AMC or bank, when you can complete the same work as a independent appraiser, or for an appraisal firm (either way you are making more and working less). It never made a lick of sense to do otherwise.
How can I do it, please help the clown appraiser out. None of the banks in this area are willing to work with independent appraisers. If you have any information, please let the Clown know. Seriously. I am trying for years, unsuccessful.
Ps. I tried VA, but I need 2 appraiser signature. Would you sign for me, if I send you 5 appraisers, just to see you sign for the one of the best in the area?
We covered marketing methodology many times before. It’s tough with lenders. They really have turned down appraisal volume to such a substantially lower level, much like musical chairs for many years now. People are holding on to their slots. You might give a fresh marketing blitz after the 3.6 deadline because there is a higher probability of many walking away or some turnover due to the technical challenges that not all will be able to so readily meet. Amc’s have in addition, redirected substantial work that appraisers used to complete such as pir’s and construction completion, other no value report needs to realty agents as a way to avoid oversight and play even more vendors against each other for even lower fees.
Find lists of top 100 lenders as if you were a consumer, develop a standard marketing deal where you can repeat the same effort down the list. Take careful documentation. Tell all of them you’re available just not if they are working with amc’s. What many amc appraisers do not realize is that many lenders whom also use amc’s, maintain private panels as well. Like Flagstar runs all initial borrower applicants through amc’s, but many of their repeat customers get their appraisals through the direct assignment platforms. The special catch is that if lenders recognize appraisers are willing to work with amc’s in the first place, they’re far less likely to make it onto the direct panels.
Play the numbers. Once you find a few good clients there is the work. What stops most appraisers from escaping amc’s is the fact they continue to work for amc’s. Because if that fulfillment was not there guess what happens, many lenders move to direct. Collectively appraisers are their own worst enemy that way. These are financial principals relating to money management and leaving yourself constant relief space so you can go months without working if you need. That’s how amc’s get you, the immediate availability. The alternate is out there. I’ve got a few appraiser contacts whom are getting a lot of traction with a great website, their phone never stops ringing, amc’s, lenders, private, the full array.
This guy is an appraiser and is pretty awesome. Subscribe and read this one. You can buy in if you really want but the blueprint to accomplish this non lender approach is also readily available on many other appraisers websites. It’s extra ordinarily easy to get fellow appraiser references. That’s why it’s important to form connections at groups, pm’s online, be there to help the local appraisers around you. Amc’s instilled this appraiser vs appraiser mentality for the exact reason of isolating appraisers so they do not communicate, network, and join together. Then they get stuck with amc work. There are endless streams of online communication with appraisers finding a lot of happiness and financial relief working with assessors, etc. Every turn you take in the lending world you’ll find increasing resistance, been that way for many years now.
https://referappraisals.com/