Per this specific sub conversation;  I believe this was argued about at length on the AF, sometime right after the CFPB’s analysis of the dodd frank reg z rules.  Read the entire reg z w/ the cfpb analysis notes. (1026.42 F) And that’s where it gets quite complicated.

If I understood it correctly, there is a safe harbor clause that the fee needs to be either customary or reasonable.  Aka Kennedy’s line; fictitious alternative presumption of compliance.  So if an appraiser accepts, the fee was reasonable by way of acceptance.

is that like the “Affordable Care Act”?

or “Customary and Reasonable” fees?

or “Public Sanitation Engineer“?

or “Internet Freedom Act”?

Richard, I am not trying to be disagreeable but I believe that you can take screen shots, tequila shots, etc. at the AMCs and report them all day to the various state boards. Honestly I believe (and look forward to) the next coming of Jesus before any government agency will ever assist us. That is just not going to happen! FACT: AMCs earn their money off of the efforts of appraisers! If appraisers refuse to work with AMCs they will go broke and go away. Those appraisers who accept assignments from AMCs are the problem! Once enough appraisers stop accepting AMC assignments….our occupation may begin to survive. Until then, it is everyone for themselves. Many appraisers like myself are semi-retired and it does not matter either way. Most of us love this business and hate to see it destroyed this way.

I am sure that I have made many appraisers who work with AMCs very mad. I do not wish to make anyone mad but as a profession we must realize that until we rid ourselves of these “MASTERS” we are doomed to ever be able to control our on professional destiny.

We have about 75,000+/- total appraisers. About 1/2 of those do residential assignments. A whole bunch of those that do the residential assignments are like me. They are at or near retirement age. I think the old dudes are just playing around. I just want to earn enough to pay for travel.

They won’t send me any more business but hey, if you want to work for minimum wage there’s always fast food and you get fed too.

Dave tell us which AMC is doing this “preferred appraiser” thingy and all of us can refuse to accept assignments from them! If enough of us refuse their work they will be toast. I promise to not accept any assignments from them if you promise the same!

Once we bust their financial azz, we can move on to the next and then next and so fourth! Works for me!

There needs to be better lender awareness that the average amc worker is likely earning more than professionally licensed appraisers.  Soon if there is not already, the order stewards will outnumber the appraisers themselves.

Corporate executives at amc’s outnumber the appraisers an average of 5 to 1, often greater.  Everyone is running the appraisal business except appraisers.

There is nothing wrong with a thousand dollar fee for appraisal services.  Get your mind around that first.  A quality appraisal takes over 2 full days to complete solo, for a wide array of challenge properties.  “see addenda” remains as codeword for dialing it in.

That’s one of the first things my step dad taught me during my 4 year apprenticeship, how bank people assign themselves fancy titles, despite not actually having professional licenses themselves.  Don’t believe the hype.