Hey Baggs, for most AMC orders I see; I try to bid somewhere in the range of 3 to 4 times more than I think they will accept. I  take the time to do that in case they are keeping note of average fees for spurious C&R ‘reports’.

Typical TAT for them is in a range of from a week-after-hell-freezes-over to about two weeks-from-never.

…except for my friends AMC. As long as he keeps paying me the same day as the field inspection, typical not overly complex C&I turn time is 10-14 working days and residential TAT can be as quick as they need it…because he PAYS enough for exclusive use of my time.

Hey Mike, what’s your fee and turn time?

Management company translation 2018: The lender we work with has already charged the consumer $X+. We do not share the consumer fee or peer fees with the appraiser and they must provide quotes completely in the blind. Cost savings from reduced cost of appraisal services will not be returned to the consumer. We reward the appraiser whom advocates on our behalf with the lowest fee, with the majority of work assignments. We are contracted with the lender at a fixed consumer fee amount, any instances of higher than expected appraisal service cost will be recognized as one time exceptions which we will cover from our general funds pool. We value our ‘partner appraisers’.

Big Boss, the move towards C&R was intended to force separated billing from amc’s while still allowing fee flexibility for those appraisers whom provided more costly specialized service in mortgage lending. The theory was if the management company is providing a valid and valuable service, the lender should pay them in addition for that service over and above what an appraiser would receive in the ‘absence of’ dealing with an amc. The rule was intended to force the amc’s to either pay fairly or for lenders to be compelled out of the interest of having competitive consumer fees, to drop amc’s and return to internal distribution instead. (aka cost plus vs cost.) The C&R rule was justified due to a sudden restriction in fair trade and access to the distribution market for appraisers. The sudden proliferation of amc’s was brought on by the now sunsetted but still present in AIR, HVCC rules. (aka separation from loan production).

Appraisers fees were cut in half. Distribution was suddenly biased based on fee. FDIC appraiser selection guidance based on skill and not fee was ignored. 130,000 or roughly 55% of all appraisers quit the industry in the next 10 years. The management companies response to this loss of vendor servicers was to then capitalize on the losses they created, promoting hybrid alternative valuation products which double their profit margin again and further accelerate licensed appraiser attrition. Amc’s market advantages were confirmed and became institutionalized when individual workers with such robust overbearing influence over the valuation process were not required to be individually licensed.

These companies establish compliance with the safe harbor rule CFPB put forth regarding C&R in Dodd Frank Reg Z rules for appraisal independence ‘because the appraiser showed the reasonableness by accepting it’ (or similar language.) Logic indicates the C&R rule was completely subverted and is currently implemented in the opposite way the spirit of the rule was intended.

“Please advise when the fictitious CFPB safe harbor rule interpretation on C&R will be rescinded.” Please advise when the counter productive separation from loan production rules will be rescinded.

Big Boss, if it were really that simple. Just like a minimum wage law assures (or ws intended to insure) that all people are protected against virtual slavery by unscupulous employers, C&R recognizes the concept in an area where public trust is critical that “You do not hire a starving man to guard the buffet table.”

If you charge 10% more than I do and we both take from 6-10 hours to do an assignment and we both do it per USPAP. Both doing our own work as we claim then so be it. Let the market dictate fees.

BUT in a system where effectively ALL the work comes out of a closed process where fees are established BEFORE the appraiser is ever contacted, and then appraiser are (wrongly) told TRID forbids subsequent negotiations; then minimum fees MUST be set to assure minimum quality is maintained. This isn’t a new concept.

While I agree re AMCs, I also know banks are NOT going back to staffing up their own appraisal departments with qualified people to handle appraisals. I look for solutions within the framework that either exists; or that can reasonably be achieved. It doesn’t mean most of us wouldn’t prefer your idea.

Finally, the ONE thing that has made appraisers jobs near impossible for decades is going to be addressed! Once this is done, protection of the Public Trust will have been forever preserved.

Ridiculous distractions like adequate fees; independence from interference by interested parties, false complaints, etc. will no longer stand in the way of the most pressing of all issues. WELL DONE TAF!!!

Remember, non qualified persons direct the ‘fee’. Persons whom would never be qualified to even be trainees now ‘manage’ the appraisal process. Professionalism in appraisal distribution is at an all time low. These people don’t return calls or emails, they brush off appraisers, get rude and push fees down. Whatever the lender wants is whatever they do, non accountable non licensed individuals.

Actually they should just let appraisers who run a business be like anyone else out there and charge whatever the hell they want to charge. You don’t like it go somewhere else. You want a cheap appraiser go find them.

C&R is in no other industry but the appraisal industry. Created by amcs and more to justify their existence and charging way above what an appraisal should cost while justifying finding the lowest appraiser. There should be no such thing as C&R. Amcs are not needed and serve no purpose period other than to save some poor underwriter time to review a report.

Until we deal with this on a FEDERAL level we will see not meaningful C&R fees. WHY should federal regulations be treated as a states rights issue? Absent federal regulations for federally regulated transactions there would BE NO appraiser licensing to begin with. It ALL started due to FIRREA – NOT because states ever saw a need.

Note the wording of the Illinois regs. Appears to exempt appraiser firms right along side commercial AMCs. So a national franchise appraiser firm appears to be exempted. For example William Fall Group? MetroWest?

I fail to see where sharted-hybrid appraisals have taken any meaningful hit at all.

Also a survey asking appraisers what they charge in FNMA transactions automatically includes fees paid by AMCs since no one is doing any significant work for Fannie without an AMC. Survey size was far too small.

It also appears Illinois appraisers are either working for minimum wages or they have discovered miraculous ways to cut out 1/4 to 1/3 the time needed for a good appraisal. 1025 for $525. Really? 1073 Condo for less than SFRs? Even though condos by their very nature are more complex forms of ownership with more variables than typical tract sfrs?

Oh. I always thought bifurcated was a euphemism for Sharted as past tense of shart.

Thanks for all you all do.

Clarocity has been the vocal promoter of these products for quite some time. If they are the brainchild behind bifurcated products, it speaks volumes about their credibility.

In case you have not followed it. Clarocity lacks the capital to cover their day to day operating expenses. Rather than pay the loan, back Clarocity issues stock in lieu of payment. The stock is at the new norm of 2.5 cents per share. Give it a month and it will be even lower.

http://www.stockhouse.com/companies/quote?symbol=v.cly

https://www.housingwire.com/articles/46149-fannie-mae-ceo-to-resign-by-end-of-year

Fannie Mae should be embarrassed that they did not learn anything from their mistakes 10 years ago. I guess that is why they are still under government control. They simply can not be trusted to do the right thing.