But you can access comments here:

https://www.regulations.gov/document/FTC-2021-0033-0001/comment

These damned amc’s won’t stop emailing me no matter how many times I ask. Month after month, year after year, across multiple platforms, the same amc’s simply never stop. This is harassment. We demand amc opt outs across the board from the tech companies, these emails come directly from mercury and scope systems primarily. Join me in my quest to constantly forward all the unwelcome amc bid quotes back to the tech companies.

Huh, have appraisers reduced their fees, are appraisers less qualified are they delivering a lessor report is the LIABILITY to the appraiser less?

VA fees in 1961 for a single sheet plus a drawing of the floor plan and verified sales was $25, FHA was $20, in 1972 it increased to $45, when I retired it had gone to $600 to $800.

MLS included only about 30% of the sales and every little city had its own MLS. The Progress began at the Assessors and recorders office, Agents lied then, and do today. My bosses counted rafter ends in judgement of house sizes, they had libraries of past jobs in the interest of accuracy.

A group of assessors from the 57 California counties petitioned legislature to make public records available to counties of over a $Million population in about 1970+- You could buy a tape from the county, re-sort it and resell specialized data.

CMDC was a group of lenders organized to republish sales data from subscribers.

Several groups met together for discussion and self help including one beginning in the 1930’s

If we are driven apart from our original goals or driven to recognize other priorities we will loose usefulness and perish.

Collect fair fees, do THE job, or perish!!!

I built my business based on a hard earned reputation, not a negotiations among business’s and politicians using undisclosed contracts, credits and fiat monies. My reports were based on verifiable-repeatable information which made me responsible, justifying my fees.

The AMC regulations add another component which already has adequate. The licenses, and codes from the individual States adequately protect thru their justice system. Compounding a Federal code with a State code confuses any constituency and the news media.

Its being submitted shortly with more.

That’s good content. But if you don’t make a comment, REVVA will play the good guy and nobody will be the wiser.

Back it up already. Submit the comment.

Phone a friend, send some emails, get some more comments on that board.

This is the first legal challenge and will probably be the last if only 4 out of 80,000 appraisers are willing to stand up against amc’s anti competitive practices. Practices which would be illegal for any other licensed person to engage in.

Amc’s have decimated the industry and intimidated appraisers to no end. Comment anonymously if you must but you must comment or forever hold your peace.

Both these AMCS got away with shenanigans and one got away operating a business that not only harmed appraisers monetarily but also by conducting themselves in a poor business manner. Has the FTC even looked into the operations of these companies? I am sure that if they did at least they would see that one of them abused their powers so much so that they should be the ones facing FTC anti trust and other violations of the laws, including not paying their panel the fees they were owed. Maybe just maybe the FTC should look into the many publicized “Customary and Reasonable FEE LISTS” that are shared online and more between these AMCS.

Once again Government is protecting the bad actors that have abused their powers, abused the laws and have left many hard working appraisers on the hook. Add to this the trade group REVVA who likes to portray themselves as a GOOD GUY in webinars and more but in reality only care about the money and memberships from their million dollar members that continue to this day to siphon money from hard working appraisers as well as hard working consumers. Has the FTC looked into the fact that AMCS will charge an unknowing borrower $1000.00 for an appraisal yet only to pay the appraiser half of that or less? Have they looked into how an AMC can charge a tech fee to the appraiser to upload a report so that they don’t have to pay for their own technology? Yet a state board trying to make things fair and correct as per the Dodd Frank law is the one under scrutiny? What this tells me is that its not about the hard working appraiser. Its about the Money, the Power and a law that was created that no one clearly understands.

The FTC should spend more time on pursuing the bad actors and the AMC sector to find the real issues going on here and let the states and their boards worry about making things fair for all involved in the valuation profession.

The FTC is clearly being persuaded by others on the outside and ignoring the facts. Facts that would show how anti trust laws are being broken by the very people they seem to want to protect.

It appears my comment is noted as received (now to 4 total comments), but is not yet visible.

It is imperative to comment but remember, scope of work issues are not what this is about.

Keep it simple and just push the one point, separated billing practices would put an end to this.

This is the first major legal challenge to the errant misinterpretation of C&R rules by the CFPB, over 10 years ago.

And it will likely be the last unless more appraisers contribute and tell their stories of the existing anticompetitive nature of current amc engagements.

FTC people are not going to bother reading this blog, they will only read the comments submitted. Submit a comment today please. There are great comments, read through them and please follow with your own.

Another problem is AMC’s also create their own appraisal guidelines that vary from AMC to AMC. An example would be AMC #1 requires 4 sold comparable’s while AMC #2 requires 5 sold comparable’s while AMC #3 requires 3 sold comparable’s and 2 active/pending comparable’s. Some AMC’s want all sold comparable’s under 90 days while others want them all under 180 days. Some AMC’s want all comparable’s within 1 mile and others want them all under 3 miles.

Another problem with AMC’s is micro-managing. Some AMC’s will call, email or text the appraiser so many times wanting updates the appraiser has no time to get any work completed.

Another problem is upload /portal /technology /maintenance fees. It’s not enough AMC’s have been taking half or more of appraisers income, they started creating fees with different names to capture more income. There needs to be one fee given to the AMC and one fee to the appraiser. Enough with the add-on “NUISANCE” fees that AMC’s keep coming up with.

Another problem is the time it takes to pay the appraiser. The AMC’s hold the money due the appraiser hostage to various degrees. Some pay within 2 to 3 weeks. Other’s, like Mecury Network offer the appraiser their money fast but ONLY if the appraiser pays ANOTHER fee to Sekady Capital to release the funds. Otherwise it takes 30 + days every time to get paid. The whole thing is a racket!