FNMA CU system challenge; Identify copied language in multiple reports, cross check that with the appraiser. The instances of this have to be in the tens if not hundreds of millions by now. They’re not typing anything, they’re plagiarizing click and go redundant language. Appraisers whom use that service should understand the next guy was delivered a mirrored type up.

Can an unlicensed person really provide meaningful contribution in terms of essential analysis and written reporting?

No, you can’t provide effective oversight if the non appraiser is outside of your office. Only if dealing with a licensed appraiser could such remote operations be considered meaningful. If one touches the appraisal, through distribution, inspection, analysis, write up, or review, one should have an appraisers license or be under direct live and constant supervision of the appraiser.

Otherwise, I want the amc to do my typing. Why not? Could I hire the lender to do that? Details…

Advocate, it demonstrates yet again that many people get their definitive news from TV and radio sound bites.

Need an investment  banker? Why not choose the ones with the pretty horsies pulling that cute ol’ stagecoach. Why they MUST be really good to keep that same business name for over a century!

Hey, does anything jump out at you?

Concur…though now we need to define “outsourcing”. Follow me on this…

Traditionally appraisers used a typist (pre computer). It was fully accepted. Indeed, it was expected since those reports could not have even one typo or visible type correction on them. A typing standard few appraisers could rise to on their own. Typists were usually hourly wage…though I also paid one as piece work when I first went out on my own and volume was very low. She was also my trainee so that the costs of training someone were also reduced.

So, are we now saying that the use of any typist is wrong, or only if they are out of the office? The first option is cut and dry. Yes or no. I’d abide by it either way.

The second becomes stickier. Can I have my employee or 1099 I/C typist do my report-typing at their home? Have I crossed the confidentiality-streams-bridge by failing to maintain direct control over all data including the mere fact that someone specific is borrowing money using their home as collateral?

My personal belief is that contracting the work out falls short of maintaining both client confidentiality and borrower privacy (GLB disclosures anyone?). I choose not to do it.

Many do use such arrangements. Hence ‘Virtual Assistants’ both in the USA and outside. Those whom rationalize VAs here in the USA don’t have far to leap in order to justify using overseas services that do the same things for less money. Though a separate argument can be made that overseas is far worse because the laws and cultural mores of right and wrong are so different. Bribes are a normal business practice in many parts of the world where outsourcing has been highlighted.

I’m prepared and content to say ALL appraisal work must be performed ‘by in-house’ personnel directly employed by the appraiser. Preferably licensed appraisers, but at least Legal U.S. residents with a legal right to work that are also located in the same state as the appraiser, so that the SAME LAWS that govern the appraiser’s actions also cover those of his/her employees. IF those ‘in house’ staffers work from home I could be ok with that too…provided they are only working for that one assigning appraiser.

I can see a LOT of possible alternative views and counter arguments.

CPI Inflation Calculator

Go on then and make one of your nifty little excel charts with this one. Requesting standard fee w/ inflation, and a second overlay of lost revenue due to service charges and middle management charges, courtesy of improperly co mingled fees. Track the income loss of this industry from 10 years prior hvcc, to hvcc, to now. Then contrast that with the growth of amc companies. A nice clean 3 line chart tracked over 20 years. Go ahead, make a visual. There is no question what the results will be. It will be more like mere proofing and not analysis. The amc’s growth has a direct relationship to our loss. It’s been so profitable, all lenders have now included overhead costs in the appraisal fee itself.

Or you could market directly and provide a counter to the amc marketing machine… I don’t care how long it takes to pay me, take a damned year for all I care. The point is that I get paid the full fee and do not share it with anyone.

Being an appraiser ain’t easy, it’s not for everyone. We are the only unbiased participator in the process. You just made an argument for salaried based lending, by the way.

Separation of improperly co mingled appraiser fees would be a good place to start.

Those jokers at the cfpb care more about protecting consumers from the cost of a single stamp to mail an additional appraisal, than they do about massive unrestrained fee skimming by management companies. ie:
14(a)(3) Reimbursement
Section 1002.14 Rules on Providing Copies of Appraisals and Other Written Valuations

That’s where it gets complicated. What does it matter anyways?

Enough appraisers engage in anti competitive practices, colluding to defraud consumers and monopolize work flow away from other licensed appraisers. Apparently they are simply going to continue to get away with it. You can bribe your way to the lions share of orders, but you’d better not charge the consumer for an extra stamp. Yes, that is what this has come down to.

Step one; Stop playing nice with the traitors of this industry whom sold the rest of us down the river with outsourcing. If you’re concerned about the future of this industry, step one is to cut off the funds to those whom create unfair playing fields, the outsourcers and those whom service them.

Dude, there was a very interesting patriot trading group episode on just that. Eric was like; So what are the Chinese saying about this? We’ve heard a lot about this from the American news, but what about the Chinese? “We can take much more pain than the Americans and they will break first.” No kidding.

04-05-18 Patriot Radio News Hour

That’s exactly the point. Nothing will change unless someone goes to jail to set the example.  As far as Wells Fargo is concerned. you have to blame consumers for continuing any relationship with them. It still amazes me how many think they are a good company and continue to do business with them.

So, Mr. Ford is correct, the other players in the game start with a “Number” that is now a fixture in the applicants mind.

Washington does need to solve the problem. Unfortunately, they have been fed so much inaccurate, bias information, they think everything is perfectly fine. Just wait, the second something happens, they will be all over this acting as if they care and forcing testimony from all players. They will ask questions, get answers and then everyone will be on the way. Nothing will become of it.

The only way things will change is for some jail time to occur.

We are currently on the cliff looking down. It fall quickly.

See the shiny AMC bauble? Keep looking at the AMC bauble. Focus ALL your attention on the evils of the AMC.

…and in the meantime the banks, MBA, ABA and ALL the other lending and funding sources will continue to price fix the fees that THEY are willing to allow the AMC to charge borrowers. The fees that are quoted by the loan officer at the time the application is taken. The fee that is ‘locked into’ TRID and that lenders AND AMCs are still telling borrowers  cannot be changed.

Baggins recent post on another  thread is the perfect case on point. He WANTED to assure the appraiser was paid more and offered to add it to his own costs up front.

I’m not defending AMCs by any stretch of imagination but lets not lose sight of the fact that there is another whole group of players equally responsible for price fixing. The lenders themselves.

The solution is in Washington DC…not the individual fifty states.

But, back to the cost of living, it is common KNOWLEDGE that costs go up yearly, in the past 10-20 years, on average 3-6% per year, while the AMC group is running out of appraisers as they try to whittle the FEE down each year to make their profit forecast happen.

The consumer is not that stupid (at least in the Northeast) OK, bad Geo poke , but I have lived in CO, FL, NC, MA and NY, so I have some idea of reality. But, sadly How do we make it public that our fees are stagnant or going down to survive?