Awesome!

Yeah. They were ready to adopt it but I think your letter and me talking really helped. I know Lynn as well as Craig and Scott. So it worked out well for now.

No time frame. They said they will do exactly as suggested and gather more info, do more research and talk to other agencies and people.

I wonder what about our GA law prompted this investigation. GA is not fixing prices like LA was trying to do.

Hey Mark, So glad you were there I am so sorry I did not realize I could be at the meeting! You addressed every good thing that I also did in my letter. I know and have met Lynn Dempsey and so I wrote him and I also wrote Jeanmarie Holmes on the Board who I know and have met. Lynn was very appreciative of the letter and my concerns and did say he would relay them so I am glad he mentioned that. Did they discuss Bid orders from AMC’s? I told them both they are the bane of our existence and they should be BANNED in our State. All bidding does is force prices down and the order goes to the cheapest bidder. I get at least 3-4 bid offers a day which I DELETE! I even sent Lynn a copy of one of these posts here about AMC’s and what Appraisers across the Country think of them! A real eye opener for them.

This is a huge win for now. I advised Lynn they can change the wording but just make sure that it says that prices can be negotiated but they have to pay AT LEAST our R & C fees and then they can pay Appraisers from that starting point upward based upon complexity, etc. As you noted they were all concerned about LA case and that case was different as LA was trying to FIX fees for Appraisers. GA was not doing any such thing. All they were doing was helping us by letting AMC’s know they have to pay R & C.

Thank you very much Mark for going and solidifying their decision at least for now. I will write Lynn and make sure that if they talk about this again I want to know when.

Did they say when they would be bringing this back up again?

You are the best!

This morning I attended the GA state appraisal board hearing on the proposed rule to eliminate the C&R fee law they have in place, you know the one that is similar to the one in Dodd-Frank.

The Ga board apparently is being investigated by the FTC for their law. They thought that the FTC vs La case was a ruling in favor of the FTC when in fact it was not and wanted to avoid any sort of notion they were price fixing or anti trust.

The Board received letters from appraisers and some others in the 30 day time frame and yet here I was at the board meeting the ONLY appraiser to show up and speak up about it.

The board president made a simple statement to start which altered my initial comment. He stated the state board was here to protect the public and not the appraisers. They are here to license and regulate appraisers. Very true.

So I processed to get my opportunity to speak and made it clear that removing this law completely would do more damage to the public but appraisers as well and the state How so? Well if AMCs have no state rule as far as C&R goes they would resort back to pre Dodd Frank days and be able to pay whatever they wanted, even lesser than they do now which would most likely result in appraisers to stop working with AMCs and create that false narrative of a shortage. It would harm the public as there may be less appraisers for lender work, faster and cheaper appraisers doing less quality work to make up for the lack of good fees thus leaving the public with more garbage valuations. It would harm the public because now we would be back to the narrative that we need more AVMS, hybrids, desktops and cheaper valuations to make up for the lack of appraisers willing to work for Pennies on the dollar.

I stressed to them that they shouldn’t be bullied by the FTC, that they need to talk with other agencies, the LA attorneys to understand what went on in the case, and many others before making such a radical decision and seek alternatives. Maybe it’s a simple rewriting of it. Maybe there is nothing wrong with it period.

I spoke about many other things as well in my time allotted to me from bid requests, trainees, AMCs leaving appraisers unpaid, and how allowing AMCs to charge borrowers a certain amount and pay themselves more than the appraiser or seek out the cheapest is not protecting the public.

At the end, the board president stated that he was prepared to make a motion to adopt the rule change and drop the law, however after hearing me speak not only as a certified appraiser and president of the AGA, along with some letters sent, they unanimously voted to table the proposed rule change and seek further advise, information and do more research before proceeding any further.

While not a gigantic win, it’s a win none the less and I applaud those who took to time to write letters. I just wish more appraisers would have m to the meeting to speak up in person.

Shout out to Mary Thompson as apparently she wrote a great letter as well that was mentioned by the board members.

It’s called the FTC and they are investigating the GA board. That is why this is being considered.

I emailed Lynn Dempsey the Chairman and one of the other members of the Board who I know and they both immediately responded and said they will make my concerns heard about this proposal. Please do you part and email DS Murphy and or Lynn Dempsey. I know Lynn he is a reasonable guy. Please see my post earlier here that discussed my concerns and what I outlined to the Board Members. Do it now. Vote is mid July. Thanks

I believe these low, below C&R, fees will work their way of the industry. If an appraiser will cut their fees then what else will they cut? Their time on producing quality, credible work? Even their ability and competence must be below par if they will take a fee below par. I’m not accepting orders that cut my fees. I’ll wait until these AMCs are gone.

Email him today and be respectful please! They are actually trying to help GA Appraisers, but this change is a mistake and not warranted.

The Bottom Line is Louisiana was FIXING fees for their Appraisers and that is what the issue was with the FTC. I told Lynn if they remove R & C verbiage in its entirety from the rule that will give AMC’s free license to reduce their fees to anything they want.

BUT here is the real issue which I also told Lynn to discuss in their July meeting… BLASTED orders. Now this is the real culprit. This is the one way the AMC’s get around paying R & C because the Appraiser places the bid. All that blasted orders do is PIT Appraisers against each other by having them place low ball offers to get that order. In this changing market with appraisal orders on the decline, the fees that some Appraisers are offering are crazy low. I believe firmly in you get what you pay for in this world. And all that these blasted orders are doing is producing sub par reports. This process of blasting undermines public trust in our end product. I don’t care who you are, if you are getting paid 1/2 your R & C fees, corners will be cut. If you feel otherwise I don’t believe you! Sorry! We need not cheapen our product by continually accepting unreasonable fees for the job we do not to mention the huge liability we are under these days!

Heck my car mechanic ($135 per hour), plumber, electrician, etc. do not use management companies. All the preceding providers work on billable hours plus cost of materials – at a much higher real rate than good appraisers.

For some clients – I provide a detailed breakdown on the time component, car mileage, other expenses that it takes to complete the appraisal. It is amazing how often it is below minimum wage. Like other professions, lets change to the billable hours plus expenses for appraisal fees.

Do home inspectors use management companies?

Maybe the appraisal fee should not be predetermined at all for mortgage/lending purposes. How is it the appraisal profession became so manipulated and controlled by AMC’s and others; while other professionals have avoided this? This probably, in part, explains why such a large percentage of residential mortgage appraisals are dreadfully low quality.

The feeble attempt at reasonable appraisal fees is a joke. Only the corner cutters can capitalize on these. Way too often the real fee should be several times the “reasonable fee”.

It is amazing that – real estate is often the largest asset people have – yet you can pay more for an eyelash weave than for a thorough/good appraisal. Messed up priorities maybe?

Um, third parties do not set the fees for your mentioned examples. VA is an example of government agency fee schedules, a survey of closing documents from a myriad of lenders where amc’s where not involved, aka real world costs from real world appraisers. That or BLM work yellow book independent contractors. Academic studies, same thing, an analysis of real world billable amounts performed by objective unbiased independent academics, aka disinterested parties from other business sectors. Independent private sector surveys, again, a survey or measurement of existing market data, and in no way ‘setting fees’.

This world is called an independent open and fair marketplace absent of amc middle management coercive fee fixing policies which harm the vast majority of all licensed appraisers. Come inside and get comfy, it’s warm and equitable in these halls where everyone is treated equally, they have independence, and are not subject to the pressures of corporations whom inject themselves mid stream into billing practices and then brag about record setting business growth to the same people they’ve directly harmed with their fee reduction policies. Third parties do set your fees if you’re an amc appraiser, because of their consistent financial motivation to profit by way of driving appraisers fees down. Where as studies are a mere reflection of open and fair competitive market fee quotes by actual independent appraisers, specifically examining the industry portions where such amc’s are not yet injected. Oh man, when lawn mowing literally pays better than 20 years of dedicated professional service… Yeah, amc’s all the way, for sure.

Um….. Not exactly. As borrowers are quoted appraisal fees ahead of time via TRID, appraisers should rest assured the lender has guaranteed that much of a fee to the appraiser at a minimum. Amc’s should not be able to step in and drive that appraisers fee down, then pocket the billable difference. There is a point where service is compromised by middle managements constant pressure to drive service fees down. This is a universal rule true in every industry. There is zero value added service from many appraisers perspective. As amc’s are staffed by non qualified persons, there is nothing they can review or suggest which is not already readily available to the appraiser from their own quality technical tools and license qualification training. Fee fixing is what the amc does, and they always fix the fee downward to increase their own profits. The exact amount is inconsequential, you can guarantee the amc has a financial motivation to pay less, not more. Because they do not bill for the amc service separately from the appraiser. The very accusation of fee fixing, that’s something an amc would say out of their own self interests. Appraisers are just trying to avoid going under because of the unfair order distribution policies amc’s have adopted, preferring the lowest appraisal fee above all other qualification factors.

Oh yeah, it’s all coming back to me now… The memories. My fondest memories involve talking about industry regulation only to learn nobody at the amc office even knew what the regulatory references were. “These are my new managers?” Managed by people not qualified to do the tasks themselves. Amc’s are instant out of the box telecom companies. No more. No less. My vote continues to be requiring an appraisers license for each and every single individual involved in any way what so ever with appraisal review, appraisal distribution, appraisal panel management, etc. Some companies do it better than others.

I gave it my best foot forward for years, the experience was not positive. At one point I tracked the time spent answering quotes vs orders gained, I was spending 2-4 hours a day on just fee quoting. One in a dozen if not far less than that hit. I was quoting reasonable discount fees at $450 and often less. I’ve had amc people forget to upload counter offers, tell me just to hit the number, sub me out if I called finals, put obvious pressure on me, entice me to use their typing services, prescribe unreasonably low fee suggestions such as $200 per report alongside more enticement of more orders, a quite long list. Are you getting near to what the consumer was charged? With which amc? At one point I was approved down the line of the complete TAVMA list. I dropped amc’s in general around the time REVVA came out. I have an appraiser pal whom long since threw in the towel and because he knows the appraisal industry so well, has even had to file complaints against amc’s from his realty position. When I moved away from amc’s I immediately had much better time management, better working efficiency, more actual appraisal production, consistent fees, about 2x income stream comparatively per order completed. There was no turning back, it was obvious that fielding orders outside of the amc arena was the smarter business decision. What is amazing is how this certain segment of pro amc appraisers thrived ahead of the rest of us by cutting in line. I’m still open to amc’s, if only there was an amc whom billed for their services separately and did not have a consistent financial motivation to drive my fee down to increase their profit margin.

My state requires appraisers to list the fee in the report.

Are you guys talking about transparent solutions in good faith?
You said; ‘every AMC report’. I have identified the primary problem.

The solution to the predatory amc problem is exactly as written in the original Dodd Frank Reg Z text. If the amc company can not carve out separated billing, and sell that to the lender, they should be fined out of existence overnight. Appraisers should not be funding amc services, because it is the lender whom selects the use of this service, not the appraiser. Lenders should pay for the amc, and hands off the appraisal fee. As amc’s do not provide appraisals, they should not be sharing billing space with appraisers. Lenders can send orders directly to appraisers while maintaining separation rules, through a variety of tech systems with minimal effort and minimal cost. Amc’s charge hundreds of dollars for that ultra simple service and appraisers take that short. Half of all amc’s working efforts are devoted to shopping for cheaper appraisers, it’s an incredible waste of time and resources.