From Dealerships to AMCs: Tech Fees as the New Normal
Last year I went to the dealership for a simple oil change. Nothing dramatic. I was prepared to drink bad waiting room coffee, scroll my phone, and leave. Instead, the service rep came out with the classic “while we had it up on the lift” routine and told me I needed new brakes. Fine. I approved the $1,200 estimate. Not fun, but expected. When the work was done, I went to pay and noticed a mysterious $60 surcharge added to the invoice. I asked what it was, and the cashier said it was a credit card fee, a five percent add‑on for using the most common form of payment on earth. I told her to call the service rep because I wasn’t accepting a surprise fee at the finish line. He explained that if I paid cash or wrote a check, the fee would be removed. I told him that nobody walks around with $1,200 in cash and that the last time I saw a checkbook was probably in a museum, and more importantly, if I had been told about this policy upfront, I would have taken my car somewhere else. He offered a coupon to offset the fee, and I paid the bill, but I also told him to let the manager know that if they insisted on keeping this nonsense, they’d be doing it without my business. A few days later, the manager called to say the fee had been eliminated entirely… proof that one person refusing to play along can make an entire policy fall apart faster than a cheap umbrella in a windstorm.
Since then, I have noticed the same creeping behavior everywhere. Restaurants adding fees for ordering online. A vet slipping in a credit card fee without mentioning it. Businesses inventing new charges for things that used to be part of their normal operating costs. At this rate, the next line item will probably be a “keep the lights on” fee so we can help them pay their electric bill.
And that brings me to AMCs and their beloved tech fees.
Chase Pursley recently asked on LinkedIn why appraisers tolerate portal fees and what other industry gets to pass its cost of doing business down as a line item. Appraisers chimed in with everything from frustration to fatalism. One said fighting tech fees is like changing the radio station while driving toward a cliff. Another said they have never understood how AMCs justify passing their operating costs to the appraiser, especially when AMCs are acting as the lender’s agent.
And here is the part that makes AMC tech fees even more absurd than the dealership’s credit card surcharge: at least the dealership was charging its own customer. AMCs are charging appraisers, who are not their customers at all. Borrowers pay for the appraisal. Lenders hire the AMC. Yet somehow the AMC’s cost of doing business gets pushed onto the only party who isn’t their customer but is still required to use their system if they want the work.
Tech fees became permanent because appraisers didn’t fight them early on. Many assumed they could simply raise their appraisal fee to offset the cost, but AMCs immediately did what AMCs always do: they shopped for whoever would accept the lowest fee with the least resistance. And now tech fees have multiplied into every imaginable form. Some AMCs charge per order. Some charge per upload. Some charge for access to their system. And some, like ValueLink, have added a monthly subscription on top of everything else. A subscription. Before you can even invoice.
It’s the same pattern as the dealership, but with a twist: a business expense gets shifted onto someone who accepted it not out of enthusiasm, but because refusing meant being cut out of the workflow entirely.
If the person pays it, the fee stays. If enough people push back, the fee disappears. The difference is that appraisers rarely push back because they fear losing the order, and that silence became permission. And once a fee becomes normalized, it becomes permanent.
The moral is simple: fees grow in silence. The moment someone says no, the whole setup starts to shake. The dealership backed down because one customer refused to be quietly taxed. AMCs will keep shifting their costs onto appraisers until appraisers decide they’re done subsidizing someone else’s business model and finally push back.
- From Dealerships to AMCs: Tech Fees as the New Normal - January 27, 2026
- When Protecting Tenants Starts With Targeting Property Rights - January 6, 2026
- “No Name” Licenses, No Accountability: From Highways to Housing - October 24, 2025
Thanks for saying this out loud. I refuse to pay any tech fees. If a fee appears after an order is accepted, I return the order to the AMC and state they should reassign because I never agreed to a tech fee. This always appears after I’ve accepted an assignment, never mentioned beforehand. My fee is always increased to accommodate the bullshit fee. Thank goodness private work is now outnumbering lending assignments.
^ This is the way
The ValueLink one is especially nefarious because in order to receive orders from YOUR clients on that platform, you must now pay a “subscription” fee – for the damn platform that the client chose. Why is the client not eating this cost and building it into the appraisal fee? How is that ethical or even legal (good question for a lawyer)?
I do
Chase, exactly. The ValueLink situation is its own special circus. As for the ethics, let’s just say they are doing the limbo & the bar keeps getting lower.
There is also the fact that these “tech fees” should be disclosed in the appraisal as it is a fee that must be paid in order to procure the assignment. How many are disclose the fees in their appraisal?
I do
Absolutely, I do. I also diclose the AMC fee (usually unknown) as an addiotnal fee paid by the borrower to a 3rd party other than the Bank or Appraiser.
Thankfully consumers do not get to review any of this fee breakdown information on their primary disclosure forms.
Score another win for the amc industry and junk fee billing practices!
Like the $499 fee the car dealer’s add on to the sale.
Tech fees and others fees are not only profit drivers, they cause fear in professionals living under serious anti-competitive threats to their livelihood. You know you should tell the truth, you should argue or refuse, but what will happen to you if you do?
Good God I have been complaining about this for about 15 years. The typical appraiser response was always “add it your fee”.
smh
Now businesses everywhere are adding these NUISANCE fees to everything. Fee’s. Fee’s. Fee’s. Some businesses can get away with it. Some cannot. We appraisers fall into the cannot category. Since AMC’s manage and control us much like children in kindergarten. We appraisers have no say in the matter if we want to be chosen for a job.
We have done this to ourselves. Both appraisers and all of society. When “they” started forcing us to use electronic payments instead of cash. When we all got stupid and stopped realizing a price posted should be all inclusive including their cost to do business.
I think it is too late to complain. We dug this hole ourselves.
Older but maybe Wiser, I get what you’re saying. Once we all stopped using cash, it was like every business suddenly discovered the joy of tacking on a “little extra” just because they could. We definitely helped create the perfect ecosystem for nuisance fees to breed like fruit flies.
But that doesn’t mean we just shrug & accept the whole circus now. So no, I don’t think it’s too late to complain. If anything, it’s too late to stay quiet. Holes only get deeper when everyone shrugs & keeps digging.
Pushing back one AMC at a time, or hoping individual appraisers refuse a tech fee, is not a strategy — it’s noise.
It’s the appraisal version of yelling at the cashier instead of changing the law that allows the fee in the first place. The dealership backed down because they were exposed to consumer pressure. AMCs are insulated from that pressure by design.
The hard truth: AMCs don’t care if individual appraisers complain. The system is built so that silence isn’t just permission — it’s enforced. Refuse the fee and you’re quietly removed from the panel. That’s not a market; that’s a choke point.
If this industry wants real change, the venue is not the AMC portal or a LinkedIn comment thread. The venue is Congress and the Consumer Financial Protection Bureau.
Why? Because AMC tech fees aren’t just annoying — they raise serious questions about:
• Who the actual customer is
• Whether fees disclosed to borrowers reflect reality
• Whether operating costs are being shifted in ways that violate consumer-finance transparency
Those are regulatory questions, not customer-service issues.
This is where the industry has been too timid for too long. Instead of fighting fee by fee, the correct approach is to force clarity at the federal level:
Who is allowed to charge whom, for what, and how it must be disclosed.
That effort is coming.
With the support of the Appraisal Institute, and voices like Jeremy Baggott, Mike Ford, including myself and others who understand both the regulatory and economic realities of this business, the conversation is going to move out of comment sections and into rooms where policy actually changes. And when it does, the tech-fee shell game won’t survive daylight. We already know what does work — we’ve seen it in the VA system.
In many VA markets:
• Fees are set, transparent, and enforced
• There is no AMC middle layer siphoning value
• Appraisers are paid customary and reasonable fees without junk add-ons
• Turn times and quality are better, not worse
That model proves the current AMC fee structure is not inevitable — it’s a choice.
If the industry is serious about reform, here are examples of changes that are actually within reach:
1. Federal clarification that AMC operating costs cannot be charged to appraisers
2. Mandatory borrower disclosure of how appraisal fees are split
3. Limits or bans on AMC subscription and portal fees
4. Adoption of VA-style fee schedules or fee floors nationally (base fee $700 is customary depending on the area serviced)
5. Prohibiting lender ownership or control of AMCs (Banks out of AMC ownership)
6. National ROV standards managed outside the AMC ecosystem
7. AMC audits tied to consumer-fee accuracy, not self-reporting
8. Clear designation of who the AMC’s customer actually is
9. Penalties for fee obfuscation and cost-shifting
10. Restoring appraiser independence by removing coercive fee leverage
None of that happens because one appraiser refuses a $35 upload fee.
It happens when the industry stops normalizing a broken structure and starts challenging it where it actually matters.
Fees grow in silence — that part is true.
But systems collapse under scrutiny, not anecdotes.
And that scrutiny is coming.
Ken, I get the big‑picture strategy, but let’s not pretend the regulators have been dying to help us out. The CFPB is the same agency that looked at the idea of separating AMC fees from appraiser fees and basically said, “Nah, that might overwhelm borrowers.” One extra line. Too confusing.
So when people say the fix is going to come from Congress or the CFPB, I have to laugh a little. If we sit around waiting for policymakers to suddenly champion transparency, we’ll be waiting forever.
Scrutiny matters, absolutely. But history has made it pretty clear that if appraisers don’t push from the ground up, no one in DC is losing sleep over tech fees.
Kenneth, brilliantly stated, and I hope that change is coming, as you so confidently assert. I wish I had your optimism, I mean didn’t the current administration just demolish the Consumer Financial Protection Bureau? I think this total cluster F about 3.6 and “ group process appraisals” ( for lack of a better phrase) will take years to UnF
They added tech fees to BPOs too. It doesn’t make sense to tell me it’s $125 with a $50 tech fee. Just tell me it pays $75! Very deceiving! 
Appraisers are not allowed to engage with free market principals, rather constantly subjected to restraint of trade conditions, we can not direct lenders where to send us orders. What previously leveled the playing field to prevent abuse? A standard market rate customary and reasonable fee, lenders and amcs were required to pay. The original intention of DF Reg Z on C&R billing which the CFPB safe harbor rule dismissed. C&R applied universally to all appraisers on approved panels. No disproportionate assignment volume, no unearned fee raking, no exclusion of many within the workforce. Missing the IVPI proposal yet?
Excel Energy utility company is now charging a substantial cost of service delivery fees to consumers. A new billing line item buried far down the list. Described as a fee for ‘necessary transportation costs in order to deliver and bring the energy to consumers’. They hold an energy monopoly, consumers have no other choices. They are overseen by a central state agency rife with conflict of interests, the board and other influential members of oversight are populated by those whom profit from consumer exploitation, many former energy industry employees. Give a few of them customary titles of consumer advocate to satisfy regulatory requirements. Consumers have no choice. Price is up, value is down. Sound familiar?
Regaining appraisal independence within gse appraisal realms is not possible due to the separation from mortgage loan production rule. Because gse appraisers can not direct lenders or consumers in any way what so ever, appraisers are instead consistently directed and exploited. Lenders maintain total control over the entire appraisal process. Appraisers play ball or they are silently removed, subjected to restraint of trade. Why lenders use grading, individual fee setting, amc’s. A cover to engage in disproportionate preferential assignment for preferred most profitable results. A regulatory side step. Valid consistently applied consumer protection mechanisms are long since effectively dismantled. Prohibitions on free market engagement instead. The illusion of consumer protection, a purely profit driven model, all that is left. What’s your fee and turn time?
Baggins, you’re not wrong… “free market” in this industry is basically cosplay at this point. We can’t choose clients, can’t set terms, can’t direct anything, but somehow we’re expected to pretend this is all healthy competition. Sure.
And your utility analogy? Nailed it. Monopolies love inventing new fees with poetic names while telling us it’s all for our benefit. Meanwhile the bill goes up and the value goes down. Déjà vu all over again.
At this point, “What’s your fee and turn time” feels like asking someone in handcuffs how fast they can run.
The system isn’t broken, it’s working exactly as designed. That’s the joke, and none of us are laughing.
Here’s my take and methodology, because I vaguely remember when AMC’s had to stop charging “membership” fees and such fees were considered a “cost of doing business with the AMC” which was classified as “prohibited” or “illegal”……. so the label changed from “membership” to “upload”, or “admin” or “tech” fee or other similar names. None of the labels contain a description of what the fee is for, so it’s clearly just a fake fee that can only be labeled as a “cost of doing business with the client” allocated to the appraiser income stream, and thus deductible and requiring additional in house accounting for the appraiser. If the “tech” fee is, say, $15 and contains no definition or explanation, I add a fee of $25 for administering the tech fee. Some pay, most don’t, but my own track record of incurring the expense and being unable to collect for services rendered is well documented and considered each April when I file. I guess when the “each” client value exceeds $600 I’ll probably start sending them a W-9 to fill out. Historically, it has not been uncommon the find that even after unilaterally deducting for a self-proclaimed “tech” fee, the W-9 at the end of the year reflects as if they paid the full fee as agreed (not as the “after modification fee”) reduced by the “whatever” fee amount. Whaddyathink? OBTW – this last week I received a “new” list of AMC charges that included even $1 and $2 charges for uploading revised reports generally charged and often based on frivolous review requirements beyond industry standards and proprietary only to the client. I have reserved the appropriate pronouns for when the time comes, but implementing an undescribed additional fee and deducting it from a previously agreed upon cost for services to be rendered need not be acceptable nor dwelled upon. Charge for it. Guess I’m lucky being rural geographically, because…… for example…… if an ROV request comes in citing additional “comparable sales” that appear on my 1 line search parameter list of properties already considered and rejected by the appraiser……. we charge for those if the client requires that the previously rejected property be considered comparable. At this point they are also bordering on issues that suggest employer / employee relationship creation which I comment on in revised reports where accommodating non-industry standard requests within the revised report.
Brilliant tax strategy. There is also a conflict of interest here. To charge for every error or revision… Guess what; More error and revision requests. More profit! It does not take a rocket scientist to see how this erodes quality and trust. Who needs an underwriter anyways? We’ve been living in a fast and loose origination climate remarkably similar to before the last crash for many years already.
There is an official IRS form people can fill out to challenge if any given company may be legally defined as an employer, and thusly liable for all missed benefits and privileges a regular employ should have otherwise enjoyed. I find it remarkable how many appraisers stayed in the amc realm and never took advantage of this obvious possibility. The guide comes complete with definitions of what constitutes an employee vs an independent contractor. Amc’s have clearly beyond a doubt crossed the line more than a decade ago. They could and should be on the hook for multiple liabilities. IRS even has a form you can fill out to ask them, based on a companies behavior and engagement, to define if the company should have treated you as an employee rather than an independent contractor.
https://www.irs.gov/businesses/small-businesses-self-employed/independent-contractor-self-employed-or-employee
Who is actually independent in the room? Most appraisers said it’s too much trouble, we will not be treated this way, boycotted amc’s across the board. But for appraisers still caught up in the amc realm, you potentially have options with the IRS. Go straight to the definition of an employee.
Douglas, your system definitely wins points for creativity. If they’re going to toss mystery fees at you with zero explanation, adding your own admin charge for dealing with their admin charge feels like poetic symmetry.
Whether it’s actually permissible… that’s where things get fuzzy. It might fly as a business expense, or it might just give your accountant heartburn. But honestly, in an industry where people invent $1 “revision upload” fees, your approach feels downright reasonable.
You know, if I was not already at times claiming a negative tax rate, the notion of itemizing the fees and tagging on my own additional business expense fee for ‘administering’ their fees, might actually work. This could serve to decrease effective taxable income. The catch 22 is due to the fees, there is a smaller gross income figure to work with in the first place.
Each individual decides for themselves at tax time. More of their earnings with less taxes, or agrees to pay the higher taxation. Risk auditing if you write off too much. Or lower taxation, more write offs, the trade off being limited to negative social security earnings contribution. Many want to post positive incomes, hold reserves, pay a certain portion to taxes as in a tradition job. Continued contribution to social security. That and not risk auditing. You can be an independent 1099 for decades and earn acceptable income, then consistently write everything off to the point your long term income tally for social security purposes zero’s out.
This is an important thing to talk about in the context of superfluous service fees. What has been passed downstream to the appraisers is far more than just ‘a fee’. What has occurred is an implementation of an exploitative process that enriches those inserted upstream of the work supply, and impoverishes and limits the growth potential of the workers downstream of these companies imposing the fees.
The upstream companies have freed up their own ability to write off expenses they never had before. By passing their cost of doing their business to the appraiser. The appraiser experiences less gross income, a reduction in allowable write off expense. If you only earn so much, you only have so much to write off. So now unless you take a negative income figure, a negative tax rate, you can no longer enjoy as many traditional business write offs such as a new work vehicle, all new technology, hardware, supplies, expanded service subscriptions, the cost of hiring and training new people.
As the parties charging these fees pass down cost of doing business expenses they free up additional expense budgets to grow their companies faster, freeing up additional flexibility. Allowing them to hire more people, increase profits, be more innovative, explore new technologies, buy equipment, etc. Otherwise if the companies did not pass these expenses down the line to the 1099 appraisers, the expenses involved with these costs of doing business would be a constant drain and occupy a certain portion of their allowable write off. Unlike an independent 1099 whom can write off unreasonable volume of expenses, a company (corporation) must show profit, for share holders, their financial standing, access to capital, etc. So they treat the appraiser as an expendable disposable asset who’s continued business viability is irrelevant to their own companies standing and income. What they’re spending their R&D budget on is automation, so once the appraisal industry is incapable of continued viability, their internally controlled automation will have complete control. They don’t want just a piece of the pie, they want it all.
The most common solution to grow one’s appraisal business under this model is volume based and franchise, which relies heavily on third party outsourcing. This is why the appraisal industry stopped growing and is retracting instead. Outsourcing basically eliminates the trainee apprentice model at the scale this industry needs to replace aging appraisers. As third party companies proliferate, a continued stream of new players upstream of the work supply readily exploit appraiser workers in this space. The appraisal trade groups, being directed by those whom benefit from the new exploitative modeling, they attempt artificial injection of new workers with parea. But who wants to sign up for immediate abuse with no viable long term prospects in a pay to play system?
Quite a different modeling and business climate than direct voluntary engagement with clientele in a free market setting without middle men. The end result of the separation from mortgage loan production rule becomes apparent. The lack of two way accountability when direct engagement occurred between a licensed loan officer and a licensed appraiser has also created a fertile ground for rapidly expanding fraud and abuse. Stakeholders.
RE: Ridiculous add-on charges.
About 3 years ago I had to buy a used car for doing my appraisal inspections. Bought a used 2018 Honda Civic. I was paying cash for it and was looking over the invoice. It showed: “Third Brake Light Safety Strobe $650.”
I asked what that was. Finance person: “it’s your third brake safety strobe that activates when you apply the brakes and reduces rear-end collisions by up to 90%”. First he used it’s “your”….as if I already owned it. I then asked if the dealer placed it there or was it factory installed? He said “our policy is to install it to provide additional safety for you”. Hmm. I did not tell him of my background in the automotive industry.
I said, take it off.
He said he could not.
I said…..Bye.
He said wait, let me ask the manager. I said good idea.
Long story short…….ANYONE can buy the part to make your third brake light flash for $20 at any auto parts store.
They took it off and I saved $650.
Looks like AMC’s took the same class the car dealers did.
smh
I actually laughed through most of this article — because the frustration is real, relatable, and honestly… justified. Nobody likes surprise fees, whether it’s a dealership credit card surcharge or yet another line item attached to an appraisal order.
But here’s where the analogy veers off the road a bit.
The appraisal world didn’t invent tech fees because AMCs suddenly woke up one day and thought, “You know what would be fun? Charging people for portals.” Tech fees exist because the entire valuation process has been forced into mandatory digital workflows — and everyone in the chain pays to participate.
AMCs pay tech fees to receive orders from lenders and transmit completed appraisals to lenders and borrowers. Appraisers pay tech fees to receive assignments and upload reports. And here’s the plot twist that rarely gets mentioned: even in direct lender–appraiser engagement, the appraiser still pays a tech fee. Remove the AMC and the fee doesn’t disappear — it just changes platforms and rebrands itself.
So while it feels like AMCs are “passing costs down,” what’s really happening is a three-party squeeze:
Lenders mandate platforms and workflows
Software companies monetize access
AMCs and appraisers pay to operate inside that system
Meanwhile, the party making thousands (sometimes tens of thousands) per loan somehow manages to avoid paying any appraisal-related tech fees at all. Curious how that keeps happening.
If we’re being honest — and I think we should be — this isn’t about AMCs versus appraisers. It’s about where costs land when the most profitable party in the transaction has the leverage to push them downstream.
So yes, fees grow in silence.
But they also grow in structure.
Most of us are on the same team here, just standing on different rungs of the ladder — all paying tolls to use roads we didn’t design, on platforms we didn’t choose, to deliver work that ultimately benefits someone else’s bottom line.
Now excuse me while I go prepare for the next exciting line item:
“Mandatory Digital Oxygen Fee.”
It has zero to do with digitalization, plenty of other industries are way ahead of us when it comes to standardization and digital workflows and they don’t bilk everyone downstream like you mentioned. The users of the software should pay for it and work it into their overall cost of doing business.
Kimberly, your comment definitely made me laugh, but I’m still not buying the premise. Mandatory digital workflows do not automatically mean every cost gets pushed to the people with the least leverage. Plenty of industries have modernized without turning every login into a toll booth or treating basic access like a luxury upgrade.
I get the structure argument, but that does not make the downstream fees any less lopsided. The idea that this is just “how the system works” is exactly how these charges multiply quietly until no one remembers who was supposed to pay for what in the first place.
But I will give you this, the Mandatory Digital Oxygen Fee line was gold. Let’s hope no one in software reads it & decides it is a business plan!
I don’t do business with any AMC’s. My Mercury and AppraisalPort clients know that every fee I counter offer includes the fee charged by the portal. They play ball, so no problems there. I’ve been in this business since 1983 and have never done AMC work. Their business model is parasitic, so I simply have taken a pass. Not sure why my peers haven’t done so as well. To each his/her own, I suppose. It’s a free country.
Cotality logo
Notice of 2026 fee increase
Dear Valued Appraisal Service Provider,
First, we want to take the time to thank you for your business and the opportunity to serve you. Cotality is committed to driving your success.
To maintain the quality and reliability of our solutions today and relentlessly focus on driving your success tomorrow, our annual price increase to your existing CMS/Ports and Mercury Network as well as updated billing triggers, will be effective April 1, 2026.
2026 Fee Increase
Service
Transaction Fee
Full Appraisal
$18.75
BPO-Interior (includes Evaluations)
$13.75
Property Data Report (PDR)
$11.50
Limited Valuation
$8.25
BPO-Exterior
$7.00
Inspections (includes PCR’s)
$3.50
AVM
$3.25
Synchronized Billing Triggers
Based on feedback on platform consistency, we are synchronizing billing triggers across the two primary valuations platforms ecosystem below, effective April 1. This alignment provides a more predictable billing cycle for your accounting teams. Valuations (CMS & Mercury Network): Billing will occur at Order Accept + 5 Calendar Days.
Note on Cancellations
To support these automated workflows, transaction fees for orders cancelled after these windows have passed will not be eligible for refunds. We recommend reviewing your order management workflows to be sure cancellations are processed within this grace period.
Investing in Your Success
This adjustment supports our commitment to modernizing our platform and providing you with a competitive edge through:
Accelerating Innovation: Heavy investment in R&D to build the next generation of appraisal and title technology.
Enhanced Security & Scalability: Ensuring your operations remain robust, fast, and secure as the market evolves.
New Tools and Capabilities: Delivering advanced capabilities to support valuation modernization and workflow efficiency.
No action is required from you at this time. The changes will be applied automatically on April 1, 2026.
We truly value your continued partnership and appreciate your support as we update our systems. Should you have any questions, please contact our Customer Experience Team or Client Success Manager.
Thank you for your continued partnership and trust in Cotality.
Best regards,
Cotality Collateral Solutions
Brilliant. This company has been a primary stake holder in the valuation services industry for two decades. Their influence continues to expand.
No more refunds for you if your client cancels an order of no fault of yours. Is that even legal on a national basis to apply such a policy? I guess if it’s in their terms and conditions.
Why do the non licensed fake inspectors get a lower billing rate?
Was their systems not secure previously?
Am I reading this right that now fees levied on appraisers go to supporting the title industry?
Good thing appraisers don’t have a choice. ‘Modernization’.
Screw all this AMC fee garbage! I just add on any and all “tech, upload, convenience, order, platform, membership” fees to my acceptance of the job or bid. Most will just add it in and accept it. Those that don’t can go suck rocks and send the order to skippy-joe down the road and screw them with their low ball fee and extra junk fee ads.
How about we add a new form tech fee, say about $300 per order.
I add all tech fees to my amc bid / quote, that way it levels out. IF they sent it elsewhere so be it, let them pay the hit fees.
I am retired, but once in awhile I check back in here just to see if I made the right decision. Yep!!!! Without question!!!! Thank you for the stark and affirming reminder. While I did not do residential mortgage appraisal work, the anti-appraiser trend will leach into all aspects of appraising soon.
Evil still rules, and increasingly so, in the anti-appraisal world. Others are laughing themselves to the bank at appraisers expense. Appraisers are and continue to be horrendously oppressed, falsely accused and are assuredly being destroyed.
Rising fees and costs are bombarding us from all directions. Even property data that used to be free or very cheap in our region has gone up several hundred %. Because of the investigative types of appraisal work I did; if I were to do those intense assignments now, in some cases, the expense for this data could approach 4-digits. I complained about this and was told to just add it to the fee, ya – right. I also considered proposing legislation that would allow licensed appraisers to obtain this information free. But finally just made the fantastic decision I should have a couple of decades ago.
But change is good: right? Well—Yes, if you are a mindless drone – until they no longer need drones.
Well said. The entire model has morphed many, not all, AMCs to bid out jobs and secure the fastest and cheapest report all the while the appraiser is taking all the risk just to stay somewhat busy. Consumers, in the end, pay more for a product that in many instances dictates the consumers loan terms (rate, Ltv ratios). I’d love to learn the amount of time, per typical file, an AMC spends on actually reviewing reports for quality and accuracy. As appraisal waivers take a bigger piece of the pie, AMCs will have to drive bifurcation so they can take a piece of the field work fee and appraisal write up fee. Bifurcation was born in COVID since appraisers were charging way too much and turning way too slow and again finger pointed at us once again for coming up short! Vicious cycle and it’s broken. As work continues to slow, many AMCs will struggle to survive until they figure a way to take more of our fees and set a ceiling of C&R fees they’re willing to accept. It’s our choice to fire them and without a panel of appraisers, they can’t really sell a valuable solution to their clients. Yet many of us, myself included, choose to work with some AMC clients. We are handing the knife to our attackers while delivering reports to a system that is designed to data mine our reports to build data sets to eliminate us altogether. We are still here today but we need to become a profession that learns to stand up for our careers and gain the public trust and demand for our services. Without us, and with appraisal waivers, many are getting taken advantage of on purchase transactions. Oddly, our office gets many calls a month requesting an appraisal given a waiver was approved on their purchase loan – it makes some very nervous especially in current value-rate environment.
Hi Susan,
Thank you for the thoughtful response — and I understand the skepticism. I didn’t expect an immediate flood of responses to the VA fees / national registry idea, and honestly, that’s not how this kind of change starts anyway.
What I put out there was never meant to be a one-week reaction or a viral post. It’s the **beginning of a longer process**: getting the idea on the table, testing whether appraisers are willing to move from complaining to documenting, and starting to organize information in a way that can actually be used.
Since publishing that piece, I’ve shared the concept with multiple appraisal forums, organizations, and industry contacts to gauge interest in a **national appraisal registry** — not just signatures, but data that shows what appraisers are paid versus what borrowers are charged. That kind of transparency doesn’t happen overnight, and it won’t come from a single blog post.
One thing that *has* changed is visibility. Given everything that’s happened to me over the last few years, I do have name recognition now — for better or worse — and that gives this effort a different starting point than it would have had five or ten years ago. I’m using that to open doors and start conversations that weren’t possible before.
On the mechanics side, I’m looking at using a simple platform like **Airtable** to handle sign-ups and data collection — something accessible, low-friction, and easy to share. The goal is to make participation simple and scalable, not bureaucratic.
If you’re willing, the biggest help right now is exactly what you mentioned implicitly: **spreading the word**. Even just pointing other appraisers to the idea and saying “pay attention to this” helps build momentum. This isn’t about optimism for optimism’s sake — it’s about methodically building something that didn’t exist before.
I appreciate you engaging with the idea and pushing back where it deserves it. That’s part of how this gets better.
Kenneth
It’s Time to Document the Appraisal Fee — and Change It
The appraisal fee structure did not drift into its current state by chance. It was allowed to change because it was never documented, never measured nationally, and never challenged with evidence. That is about to change.
Work is underway to begin organizing licensed appraisers nationwide around a simple objective: document what appraisers are actually being paid, aggregate that data nationally, and determine whether there is sufficient professional support to formally challenge the current fee structure through a verified petition and organized outreach to policymakers.
This is not another discussion thread. It is not another opinion piece. It is the first step toward building a national, credential-verified record of appraisal compensation — one that can be delivered to the appropriate regulatory and oversight offices with facts instead of anecdotes.
Before explaining where this effort is going, it is important to understand how the appraisal fee arrived where it is today — especially for those who entered the profession after the last housing crisis.
________________________________________
How the Appraisal Fee Changed — Quietly
There was a time when an appraisal fee meant exactly that: the fee paid to the appraiser performing the work.
Before the 2008–2009 mortgage meltdown, appraisers invoiced for their services. Their compensation was visible in the file. Fees varied by market, property type, and complexity, but they generally supported experienced practitioners, thorough analysis, and reasonable turn times. Appraisers competed on competence, credibility, and local market knowledge.
Then the system changed.
In the aftermath of the housing collapse, appraisal management companies rapidly expanded from a limited administrative role into a dominant position between lenders and appraisers. In the name of independence and risk mitigation, the appraiser’s direct relationship with the lender was severed, and the appraisal fee was bundled into a single charge paid by the borrower.
One critical detail disappeared in the process: the appraiser’s invoice.
What followed was predictable. Without invoice transparency, appraisal fees became standardized and compressed. Appraisers were asked to do more for less, faster, and with greater liability, while borrowers continued to pay appraisal fees that often bore little resemblance to what the appraiser was actually paid.
For newer appraisers, this system feels normal. Many have never seen an appraisal invoice included in the file or known what customary and reasonable compensation looked like before fees were bundled and hidden. For more experienced appraisers, the shift was unmistakable — and cumulative.
Across millions of federally related transactions over more than a decade, even modest per-assignment fee compression represents a substantial transfer of compensation away from the professionals performing the work. Yet because this change was never documented at scale, its magnitude remains largely invisible to regulators, policymakers, and the public.
________________________________________
Why Documentation Comes First
Complaints without data go nowhere. Documentation changes outcomes.
The purpose of establishing a national database of licensed appraisers is straightforward: replace speculation with evidence. Participation would be credential-based. Anonymous claims are not the goal. The goal is to determine, by state and market, whether appraisal fees have become structurally disconnected from the work required to complete the assignment.
If sufficient national participation exists, the next step is equally clear: organize that documented interest into a formal petition and place it in front of the appropriate decision-makers — not as rhetoric, but as verified fact.
________________________________________
What Needs to Change
As this effort moves from discussion to documentation, three issues consistently rise to the surface. These are not abstract complaints. They are concrete structural problems that can be measured, evaluated, and addressed.
1. Restore transparency by returning the appraiser’s invoice to the appraisal file.
Borrowers are charged an appraisal fee, yet the portion actually paid to the appraiser is typically removed from the file. Reintroducing the appraiser’s invoice would restore basic transparency, allowing borrowers, lenders, and oversight bodies to see who performed the work and how the appraisal fee was allocated.
2. End the race-to-the-bottom fee model that disconnects compensation from scope and risk.
Appraisal fees have increasingly been compressed and standardized, regardless of market conditions, property complexity, or liability exposure. This dynamic favors speed over experience and undermines appraisal quality. A fee structure that reflects scope, market conditions, and professional responsibility is essential to long-term stability.
3. Use existing federal benchmarks to define customary and reasonable fees.
The Department of Veterans Affairs already employs regionally adjusted, published appraisal fee schedules that reflect local market conditions and customary compensation. These schedules provide a proven reference point for transparency and reasonableness, rather than leaving fees to opaque and inconsistent practices.
Together, these three changes form a practical framework for restoring transparency, sustainability, and confidence in the appraisal process — without reinventing the system or relying on speculation.
________________________________________
This Is the First Step — Not the Last
The appraisal profession has spent years talking about fees. Talk alone has not changed outcomes.
Change requires organization, documentation, and a willingness to act collectively. This effort represents the first serious step toward doing exactly that — beginning with transparency, building a verified national record, and converting professional consensus into documented evidence.
The purpose of collecting signatures and compensation data is not symbolic. The information gathered will be aggregated, verified by license and geography, and organized into a national record that demonstrates how appraisal fees are actually structured in practice. If sufficient participation is achieved, that record will be formally transmitted to the appropriate policymakers, regulators, and oversight offices responsible for mortgage finance, consumer protection, and appraisal standards.
In other words, this is about moving appraisal fees out of private frustration and into public, documented fact.
If appraisal fees are going to change, it will not happen by accident. It will happen because appraisers decided to document reality, stand behind the data, and insist that the fee structure reflect the scope of work, professional responsibility, and risk the profession carries.
This is the beginning of that process.
What follows depends on whether the profession is ready to move beyond words — and finally act.
The next step depends on whether the profession is ready to move beyond words — and finally get this done.
Kenneth J. Mullinix, Real Estate Broker
Certified Residential Real Estate Appraiser – California OREA #AR027585
Owner / President – KMA Real Estate Services
Appraisal • Inspection • Brokerage • Construction Consulting
FHA & VA Approved | 25+ Years of Experience | High-End & Waterfront Specialist
General Building Contractor CSLB #752435 | CA Real Estate Broker #01278660- inactive
Author & Industry Advocate – Working RE Magazine Contributor
kjmull@aol.com
Let’s talk to the robot, why not. post quote; ‘Reintroducing the appraiser’s invoice would restore basic transparency, allowing borrowers, lenders, and oversight bodies to see who performed the work and how the appraisal fee was allocated.’
Response; Lenders know total fees for every loan processed this entire time. The regulators are in on the action, which is why they refuse to demand transparency. Never so much as a whisper to audit the amc industry whom should have retained all these records alongside, being legally obligated agents and representatives of loan originators. Rotational fairly balanced appraisal assignment was quietly shuffled away when the HVCC rules were transposed into DF Reg Z AIR, less the one requirement which did not make it’s way into the DF Reg Z regulation, which was present in HVCC; to be required to notify the appraiser in writing why they were removed from the assignment panel or deal with reductions in work assignments. Amc’s conceal the now institutionally accepted blacklisting under the pretense of fee and turn time quotes as well as oftentimes fictitious performance grading. Enter the constant stips and overly critical administrative review of everyday working appraisers reports for no apparently productive reason, constantly stalling out what could have been a more efficient process. That happens to provide cover to fulfill the primary objective of leveling constant valuation pressure, blacklisting, silently benching, or otherwise removing those appraisers whom do not function primarily as advocates of the lender and amc’s interests. The data to accomplish these stated objectives is already present. Those in charge of mortgage lending production, including those tasked with the illusion of providing oversight, refuse to look at the data or assemble it in such a comprehensive transparent way. That which shall not pass; An audit.
Missing the IVPI Proposal yet?
https://www.workingre.com/wp-content/uploads/2013/08/IVPI-Proposalfinal.pdf
When the CFPB is finally disbanded, the C&R rule comes into full effect. However this will mean nothing as the independent model the appraisal industry utilized to engage with GSE’s, the Customary and Reasonable compensation rule revolved around, a mirrored VA engagement model, is no longer functioning or present. There is no will to enforce, the fundamental mechanisms of engagement changed. A body of oversight and managerial persons whom are benefiting from the current system of applied restraint of trade on their competitors. The corporations whom direct them having devoted substantial resources and investment in automated technology to reshape the landscape of valuation products. A means to reduce oversight, siphon away the income base of the independent businesses. Permanently obscuring any meaningful standardization process which would indicate straightforward fee for straightforward service. The decade and a half long blitz of stakeholder directed changes which essentially nullified TILA, compromised GLB, sidestepped AIR, capitalized from and directed the unlawful USPAP alterations in violation of administrative procedural codes. Started with separation from loan production, moved to rising demins, codified evaluation and hybridization into GSE approved appraisal process, cumulated in the end with the AVM final rule. Enter property data collectors, hybrid forms, value acceptance, the tolerance and promotion of the franchise model which relies heavily on third party assistance, typing services, outsourcing, unlicensed laborers. Now that all that is accomplished the FHFA at the behest of the GSE’s ushered in increased automation, a new one size fit’s all appraisal form which can no longer clearly indicate a precise fee schedule for different varied working efforts which previously claimed their own unique fee for their own unique form.
Just about the only thing not going as planned is the recent presidential order which prohibits institutional investors from being so heavily invested into residential real estate. As the current bubble bust cycle is now resulting in an increased default rate which was meant to funnel these real property holdings directly towards institutional investors whom staged this entire system (stakeholders). To acquire those real properties, from the auction block all the way to the top of the ladder with the FNMA Whole Loan Sales program. Bear in mind the figures posted for finalized auctions in the disclosed Whole Loan Sales webpages are only defaulted principal borrowing amounts, not the total real property value at the time. Nobody asks for this data relationship to be transparent either. The wealth transfer away from the citizenry is tremendous. Ask the AI bot to extrapolate the actual market value for all the properties, the totality of documented whole loan sales program back to the beginning, circa 2015, in addition to tallying the actual defaulted principal amounts. Then examine the correlation with the rise of and the tolerance of the amc model along this same time frame. 2013 is when the CFPB nullified the C&R rule and the real changes away from independent engagement modeling started taking place. Seeing the big picture yet?
Appraisal modernization. Somehow I feel that all of this has been clearly laid out before over the past two decades. Anyone still believing this is an honestly ran system or that people whom are in charge of oversight are actually doing their jobs in an ethical manner is not living in the same reality as the fifty to sixty thousand remaining appraisers whom refuse to work with amc’s, the additional forty thousand whom left the industry. The untold volume of appraisers whom never came into existence due to these operational models which deflected new professionally and ethically minded participants away rather than attracting them, representing likely well over a hundred thousand or more people whom could have been holding appraisers licenses today but are not present instead. Many appraisers whom stayed lost out on millions of dollars worth of income and working opportunity per each individual licensee. This country experienced the most volume rush of origination ever, yet appraiser licensee attrition continued. Explain that. As lenders used the ethical principal against appraisers, falsely claiming the lack of available servicers as the key justification for further automation and central control expansion, even more thirty party inclusion.
The funny part is now online appraisal boards are chalked full of PAREA students whom complain how woefully inadequate the training programs are. They’re being constantly drained of resources, charged more for the courses, materials, education then advertised. Immediate exploitation. Once these faux educators have their money, students are reporting the educators do not provide reasonable mentoring or guidance, tell them to seek help from fellow unlicensed students whom also have no real world experience or training. The PAREA students appear to have lingering suspicions this industry is not what they were sold it would be as they participate in dialogue and do their best to interpret polar opposite contradictory messages from the amc’s and appraisal trade groups, vs most actual appraisers in the field. Including immediate denial of being placed on approved appraiser panels even though they have licensing. Reporting they’re being told they still need to work under a mentor for years. They hear the stories of the disappointed and disheartened daily appraisal worker in the real world of lending, the abuses and inadequate compensation of many clients from lenders to amc’s. An immediately uncertain future with illusionary opportunity. Cut throat competition from day one. Then some idiot amc person or appraiser whom actually benefits from collusion in this model will chime in with the carrot and stick routine, brag about how much income they’re making or how easy it is to get on with the big amc’s if you just keep begging for their acceptance. There are people right now claiming decades of panel manager status whom are instructing new and would be appraisers how they can become ‘a favorite appraiser’ whom gets ‘preferred volume’ in this system. Probably the same appraisers whom subscribed to the Appraisal Coach back in the day. Nobody ever does anything about it, nobody ever loses their license. ‘Ethics in the appraisal industry.’
https://capitalmarkets.fanniemae.com/whole-loan-sales
https://appraisersblogs.com/fannie-mae-fraud-and-abuse-exposed/
Post this image again I suppose, the same thing keeps happening under similar, but varied models.
Received this from you know who today:
“Note on cancellations
To support these automated workflows, transaction fees for orders cancelled after these windows have passed will not be eligible for refunds. We recommend reviewing your order management workflows to be sure cancellations are processed within this grace period.”
Organized crime.
Borrowing consumers will get refunds for services not rendered. Appraisers will not.
Not like this company or the others involved in this client network has a track record of creating exploitative billing opportunities out of thin air. It’s not like the process of cancellation is completely out of the appraisers realm of influence and control. And it’s not like the average days until cancellation almost always is longer then their stated grace period. It’s not like that.
Guess who’s going to be getting a lot more cancelled orders, that only cancel after the refund grace period expires. Appraisers should start paper mailing or emailing invoices for the lost order acceptance fees the appraisers were required to pay, billed directly to the lender, to cover their losses. Corelogic can’t stop appraisers from billing lenders. They can only stop you from doing it on their proprietary systems.
Corelogic could have gone with a credit system. Or had a different billing structure. And only cashed in the credit or finalized the order acceptance cash payment upon COMPLETION of the assignment. Those choose not to.
The name of the game is maximum appraiser exploitation. Appraisers have no representation. Appraisers have no other options. Because appraisers dealing with mortgage lenders under FRT rules have no real independence. Courtesy of the separation from loan production rule. This is much better than getting orders directly from a licensed mortgage broker via fax or email and not paying fees, much much better.
The day of reckoning will come sooner than latter for AMC’s gouging billions of dollars from the appraisal industry and appraisers especially since 2008- mark my words. I have a intuition about this.
If any profession in this country is owed reparations… it is the Independent Fee Appraiser. Thank you sir!! May I have another!!!!!
The tech fee model survives because appraisers are renting access to platforms that profit from their data. The fix isn’t negotiating fees down — it’s changing who owns the infrastructure.
If appraisers owned their tools and their data, there’s no portal to charge access to. Your comp library, built from your own work over years, has real value — but right now that value flows to the platform, not to you.
That’s the model we’re trying to break. Appraiser data stays owned by the appraisers who create it.
Well Mr Powers, you’re about fifteen years late to that particular party. A few older article references for you.
https://appraisersblogs.com/corelogic-big-corporation-vs-appraisers/
(My day as an appraiser.)
https://appraisersblogs.com/corelogic-antitrust-concerns
(read marions comments on this one.)
https://appraisersblogs.com/corelogic-alamode-facebook-privacy-play
(It actually does not matter if we check this box or not, they take the data anyways. Smart Xchange rolls an automatic search to match every time we enter an address regardless, even if we’ve turned comps sharing completely off. It’s always on in the back ground. There is a glitch that if you use the grid offline, the software kicks out a standard pop up that it could not access the shared database.)
https://appraisersblogs.com/corelogic-acquisition-appraisers-ditch-a-la-mode
(The epic betrayal of this industries lead family business appraiser advocate whom developed both alamode and mercury systems, Dave Biggers.)
https://appraisersblogs.com/gse-executive-boasts-scheme-2-slash-appraiser-numbers/
They want the appraisers in mortgage lending gone. Value acceptance has become one with ‘the avm final rule’.
Somehow in the final rule publishing, they’ve changed many things. At first upon comment period there was a clearly stated avm final rule, the proposal and language. Now you get the interpretation instead of the rule. I’m not sure exactly how this is supposed to work but seems to have been handled different than the other rulemaking proposals in terms of final publishing. They just pushed this through last minute at the end of the appraisers are racist slander. The PAVE task force was really leading to a justification to push the avm final rule. That’s what it was really all about.
The entire appraisal community, being on one side of the racist accusation issue or the other, or dealing with false accusations and loss of work, for the most part, let the avm final rule slide through under the radar. Despite it being the most influential new rule to hit the community since rising demins which cut the workload in half, and the previously botched interpretation of C&R rules by the CFPB, which was meant to reform or eliminate the amc industry, instead allowing the exploitation to reach new levels with record setting business growth of the amc companies.
You’re not seeing the big picture here. There is no way to scrape the data back. Even all the way up the ladder at the fnma cu system, the data is correlated and monetized. Amc’s and corelogic, among others, have a hand in the data every single step along the way. I use corelogic Matrix MLS, it’s the only option available. If MLS is not directly tied to Corelogic, they likely somehow incorporate Realist systems there too, also a Corelogic product.
From initial data input, to software relations along the way to development, through processing and review, to final disposition in the FNMA Collateral Underwriter database, the concept of intellectual property rights has been absolutely demolished. Along with most of the principals that GLB consumer privacy rules were founded upon.
Don’t worry, lenders whom use internal avm’s in this manner will fill out a one or two page form every other year to self certify their product is just as reliable as a full service appraisal, from the now abolished model of reports completed under AIR valuation independence rules without unnecessary third parties whom basically control valuation opinions these days. It’s a pay to play system now; play ball or ride the bench. Restriction of trade rules the day. Consumers are the most harmed by the lack of independent checks and balances systems. You’ll just have to trust the central planners to be honest and transparent. More importantly we are instructed to believe they are honest and ethical, because they don’t have to answer to anyone anyways.
https://www.regulations.gov/document/CFPB-2023-0025-0001
(supplementary information, along the scarce 30 letters for a rule that will change the world.)
https://www.federalregister.gov/documents/2024/08/07/2024-16197/quality-control-standards-for-automated-valuation-models
(good luck figuring out what the actual avm final rule is.)
https://appraisersblogs.com/fannie-mae-2-state-of-maryland-drop-dead/
(you’ll just have to trust them to be honest.)
https://appraisersblogs.com/fannie-n-freddies-offshore-gambit-imperils-privacy-of-millions/
(AI data scraping appraisers interior home photos. Part owned by an amc exec appraiser whom also sits on state appraisal boards. ‘The clip board is dead. All your data belongs to us. Sincerely; Tony.’)
Appraisal modernization. The only full work an appraiser gets in the origination realm these days anyways is super high liability from poorly qualified borrowers. All they really need or want is a guaranteed thumbs up, and copy of the appraisers insurance. The neat part is how the system changed incrementally over two decades. The amc appraisers left in the game still think they’re independent and think they’re providing a valuable service. Until they’re suddenly not, sol left high and dry. That’s where fifty thousand licensees went and it’s near impossible to attract people to this industry. The problems are primarily rooted at the managerial levels. If you put something out there that bypasses their control structure, they’ll write themselves a new rule to get around it.