Quoting Fee/TT to AMCs
Appraisers, I had a revealing conversation with a clerk at an AMC last week. I actually received an email requesting Fee/TT, then awhile later a phone call about the same property, from a different clerk. I decided to call that clerk back after researching the property.
Conversation went something like this:
AMC clerk: Hi, this is James.
Me: Hi James, I’m calling about the Timbucktoo property, which I can do for you.
AMC: OK, I have that pulled up.
Me: First of all, I don’t discount my fee for anyone, including your AMC. Second, I can do the assignment, probably inspecting next week, but the DD will be the following week due to other assignments I have and the holidays. My fee for this will be “Y.”
AMC: slight pause, then a chuckle. That’s interesting. Other appraisers have quoted basically the same fee.
Me: Yes, isn’t it interesting that appraisers in my area actually talk to one another occasionally. We pretty much know what C&R fees should be in this region, and most of us do not discount. Generally most fees for basic subdivision homes fall in the range of “X to Z.”
AMC: Yah, that seems so. OK, I have this info recorded and will send it on to the lender.
Me: What was that again? Did I understand that you’re just collecting Fee/TT info from appraisers and then the response list is sent back to the lender?
AMC: Yes. If they get back to us, and like your quote, we can send the order along.
Me: Well, I hope the lender understands we appraisers take assignments as they flow in, and don’t hold time on our calendar under a presumption of getting an order.
AMC: laughs. Yah, I wish we could get the lender to move quicker.
My point in sending this message is to identify the REAL problem with mortgage lending appraisal order assignments: It’s the lenders who fiddle with the process and impact what appraisers are paid, and the overall timing. Lenders who use this procedure are SLOWING DOWN the loan processing. And it adversely affects appraisers.
Back in the day, not too long ago, before AMCs sprouted like mushrooms in a damp forest, the lenders had personnel in place to rotate assignments among their vendor appraisers in a particular area. Everyone knew what the fee would be, because it was pretty standard across the country – with known regional differences. (That’s basically what the Dodd-Frank C&R law was trying to do, before the Federal Reserve Board inserted the ‘other fee analysis’ option.) Turn times were generally acceptable at around one week, or at the most, two. Business relationships were also developed and appreciated.
Now lenders play AMCs off one another (because they often use more than one), and seek appraisers who don’t understand what appraisal work should cost (i.e., the fee), and churn reports out the door in far less time than should be taken to produce a quality product. Nowadays, there is almost no true business relationship between the AMC and the appraisers on their panel.
Think how much better it would be if the lenders would just say to the AMC: Hey you, we have an assignment in Timbucktoo, and we need the report back in 10 days or less, at an acceptable fee of “Y.” And by the way, Mr. AMC, we’ll pay you a handling fee of “A” to get this placed with an appraiser on your panel. Now goodbye, and just get it done.
Lenders are the ones responsible for this mess we are in, which includes many appraisers reluctant to do lending assignments placed through AMCs. It’s on the lenders shoulders. AMCs are really the small cog wheel in the entire process – an unfortunate necessary evil because lenders abdicated their appraisal ordering responsibility to outsiders, when they were not required to do so when the HVCC was mandated. Quite frankly, being an AMC is not a good position to be in now, nor has it really ever been.
Fortunately, some, but not enough, responsible lenders have begun to realize the fallacy of their ways. They have begun to jettison AMCs and are back to placing their own assignments internally, or perhaps by using a non-AMC portal. That’s a good thing for them, and appraisers.
Dave Towne on e-AppraisersDirectory.com
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Pitting Appraisers against one another via quotes, turn times, metrics, report cards is all bullshit. Just send over the order and pay us customary and reasonable fees. They have successfully divided us. The have successfully created the perfect master/slave relationship. What truly sucks is that WE allowed them to.
Dave, it’s never been about proving one’s point (knowledge, experience, support for complexity fee, due date, etc.), but rather it’s all about the lenders and their hired puppets shopping to save a dollar, or dollars, millions of times. In my single county of practice, where there are 900+ licensed appraisers (all within 25 miles of me), it seems as if they are okay spending days and or weeks going down the list of appraisers to find a single yes to the predetermined TRID fee.
It’s never been about spending the borrowers money in a professional public trust kind of way, but rather how much can the lender and or AMC profit.
Seek the truth.
‘If appraisal management companies don’t know what a fair fee and turn time is already, we can’t help them.’ If you dig deeper, you’ll find that many amc’s operate on such a basis, that quotes which exceed operational margins are not even sent to the lender. I’ve been in contact with several former amc employees and they told some stories. Bending over for lenders interests, railroading appraisers and unfair favoritism, commission based structures dependent on driving appraisers fees down, lenders sending a singular request to multiple amc’s to see who could drive service pricing the lowest, company mandates to seek over 50 quotes per individual order. The beat skips on.
While they “have successfully created the perfect master/slave relationship”, some smart appraisers refuse to be slaves to their games and found work outside of this arena. The question remains, how many will continue to be slaves? It was out of the ashes of the Great Depression that made Appraisers vital. So will it be a similar event in the future to Make Appraisers Great Again?
Just got a quick question. I’ve been an apprentice for 4 years and just got my certified residential license. I am currently working on getting my DBA, E&O insurance and getting setup with MLS. What ways can I work outside of the AMC rat race? My supervisor taught me well on how to do the work but not on exactly what types of work I could do with my new license. Any help is greatly appreciated. Thanks.
Jason:
Depending on your state and county –
1. Property Tax appeals – Learn your county rules THOROUGHLY
2. Reach out to area brokers. Have classes for small offices. Offer reviews (tricky – can’t nitpick reports but on egregiously wrong results and bad reports help them process appeals (watch USPAP compliance in this).
3. Area brokers for estate and gift tax (you can find what you need on my website – Estate and Gift tax/ IRS & value definition tabs). Learn the difference between Form 709 (gift)-special requirements; 706 ESTATE Special requirements and so called date of death appraisals-no real special requirements.
4. Become an expert on 2-4 units. Many appraisers are afraid of them.
5. Too soon for regular EW work but you can start building relationships – go after divorce work first. Go to court and WATCH a value trial! Also go to your state Administrative law Court and observe a license violation hearing.
6. AT this stage you can’t avoid AMC work, but make sure you don’t get married to any one amc – spread it out. 3 to 5.
7. Use meta tags on your web site. (they don’t have to be visible -type them in black on a white background then afterward change the font color to white so they can’t be seen. Computer searches still see them. Use every imaginable appraisal related, tax related, law related value related term and phrase you can think of. Even if it goes into whole pages after your main idea page on your site. Submit website to search engines. Make sure home page or payment page is an https secure page or google blocks some searches
8. Find out where other appraisers are in your area. Meet regularly for coffee. Net work. LISTEN to what others are doing even if it’s stuff you don’t want to do.
9. Avoid hybrids; desktops, crappy fnma desk reviews
10. Join your local mls board become an appraisal realtor(r) and RAA designated through NAR (about $400 a year for the designation).
11. I’d also join AGA (American Guild of Appraisers (AGA) #44 OPEIU, AFL-CIO. Full disclosure I’m an executive officer there. When you get in trouble as long as its not an actual integrity breech we’ll help you to fight it. Contact janbellas@appraiseersguild.org and tell her I referred you to join. We also offer free ongoing mentoring to members.
Good luck! Never compromise your professional integrity, even when it costs you money. You’ll be glad years down the road.
Thank you very much for the information. Do ya’ll have an idea on which AMC companies are the better ones to get approved by. In my state of Kentucky there are 100 AMC companies approved by the state and I only need 3-5. Any suggestions would be great. Thank you in advance.
I’ve been appraising for 27 years. I hate the AMC model as much as anyone else for numerous reasons. But how is an AMC any different than Angie’s List, Home Advisor, Lending Tree? As a contractor you have to meet their qualifications, screenings and have a license & insurance on file with them. The consumer (bank) submits what project they need done. The provider gives a list and the consumer picks 3 or 4 potential contractors (appraiser) from the given list. The consumer asks for a quote and when can you get the job done. Why do appraisers think their contractor service is different? I know blasphemy, right.
Because none of the mentioned advertisement and review platforms charge consumers up front before procuring the service contractor, thereby creating a financial incentive to drive down contractors fees and drive up consumer fees so they can pocket the difference in secret. You are confusing independent contractors with employees.
No, not blasphemy Seneca – it just bears no relationship to how it actually works – except for Relo’s.
Normally, the consumer has no say in appraiser selection whatsoever in the current AMC model. Nor is there ever any back and forth between AMC and appraiser BEFORE the consumer has been quoted a fee. Not ever. Usually or at least often, no property research before a quote. Under TRID most lenders will not requote closing costs when it is learned the property is far more complex than a routine quote would cover.
The reason for that is more philosophical than practical. They COULD redo the TRID easily. Mortgage brokers learned long ago that any time they have to go back to the consumer and ask for more money, ‘their deal’ just became shakier and since there is zero integrity among brokers preventing them from stealing each other’s clients, in the first place (almost all loans in process result in borrowers being contacted by competitors – amazing how that happens!) no one is willing to add ‘unnecessary risk’.
They’d rather send an unqualified low fee appraiser, or cause delays to the loan while the AMC shops a cheaper fee somewhere.
Best wishes for a Happy New Year to all.
Most appraisers would benefit from getting educated how the lending and AMC business works. Of course as soon as someone explains it, there will be a dozen or so who will deny that’s how it works.
TRID drives the fees. So if the loan officer quotes $650 to the borrower…the fee is $650. Even if it’s a complex file on the ocean front. Now, there is a change-in-circumstance clause which we evoke for these complex files. But if the Lender doesn’t think it’s complex, they won’t approve the fee. Most lenders pay the extra…or the AMC pays the extra…but the consumer doesn’t typically have to pay the extra.
In an effort to make the system more transparent it made it more complicated and ridiculously unfair. If you have an AMC who doesn’t care about their clients or the appraisers, then you get to shop til you find the lowest fee. So then there is a perceived “shortage” of appraisers.
Loan officers who don’t research the property prior to quoting the appraisal fee or who don’t reach out to an appraiser, lender or their agent should be required to pay the difference in the fees. THAT would fix that particular problem immediately.
And most AMCs don’t know what qualified appraiser is because they handle too large of an area (how can you possibly know all 50 states?)
They’ve got people for that… When your ‘manager’ whom becomes in charge of your entire career and business future with a formerly trusted lending client, needs to have only 1 year customer service experience, a high school diploma, is on the god awful heavy outbound calling line position, has a listed job requirement to drive down appraisers fees, and is also supposed to vet and qualify licensed individuals for compliance with government and lender regulations they know absolutely nothing about and never will…
It’s a bird, it’s a plane, nope, it’s a disposable telecom worker at the absolute bottom of the employment ladder just over a janitor… Amc’s are such great companies, friend of the appraiser!
If you can’t meet the more stringent job requirements, they’re always flexible. High staff turnover and all, typical for outbound line work. These companies are out of the box telecom and all one needs to do in order to see past the amc company lies and lines is review their employment listings and employee review data. attachment 2.
Good explanation, however, it goes beyond that. There is outright price fixing among banks/lenders and the AMCs. Amazing that so many ‘independent’ fee quotes are $650 nationally. It’s naive (I don’t mean you on this) to think Banks don’t dictate which AMCs must be used and how they, in turn, tell Loan Officers (another meaningless misnomer) what the gross fee is that must be quoted for the TRID…all before any appraiser has researched assignment complexity.
There is no way that AMCs OR lenders are verifying specific appraiser competency for specific properties AS REQUIRED!
Check this find out. I’m relatively sure this was not intended to be posted online. Print it if interesting… “hvcc” lives on, and on, and on, and on, and on.
http://www.homefirstmortgage.com/Files/Lenders/AppraisalOrdering.pdf
Here is a good analogy for outsiders. My wife is a senior medical assistant at the hospital, I’m always hearing this and that about seniority, float pool subs, and the typical hierarchy of a traditional working environment.
“Imagine if certain normal duties for the backstaff was outsourced. Then picture this third party company hiring a day one noob person, and suddenly even though they have no experience and inadequate qualifications, they’re your instant manager and could drive your hourly wage down at their discretion, set you to part time or fire you, depending on how big of a commission they desired that month and how they felt that day. And of course, no union protection and you lose all retirement benefits instantly.”
Just wanted to add that I have also been told by actual AMC employees that this process of passing around an appraisal order to multiple AMC’s and even national appraisal firms who have all agreed to keep appraisal fees within a certain range.
The amc’s have a financial incentive to ignore fdic selection guidance because the further down they drive service costs, the more cash they get to rake off the top. Nobody can quite figure out how to effectively regulate a set of middle management companies which are not necessary in the first place. The C&R rule was supposed to solve this by fining them out of existence if they continued to defraud consumers and appraisers alike with these coercive assignment and billing methods.
If only a group of senior appraisers would complain through adjudication and perhaps get this fictitious safe harbor interpretation of C&R fee rule with the cfpb removed or revised… House of cards. CFPB consumer complaint links below. Amc’s have turned appraisers into customers and have broke just about every traditional expectation of trust when it comes to fair billing and fair operational practices with the mortgage lending customer, the mortgage lender themselves, and the appraiser customer.
edit, link blew up.
http://appraisersblogs.com/coester-vms-bank-accounts-seized/#comment-24289
CFPB adjudication complaint forms and links above.
Hey….follow my lead. NO one does an appraisal for any management company until I do one. Since I will NEVER do an appraisal for a management company that should substantially reduce the income for AMCs. Come on, let’s try it for a few years! Heck, just try it for 6 months!
I received an email for a guy that seemed very nice. He was wanting to order three appraisals on vacant land. The appraisals were for 37% ownership in each tract. No timber or mineral value. He said that he had sent this assignment to several appraisers and that they turned him down. I quoted $600. for each for a total of $1,800….Keep in mind that I am retired but I thought GEE, why not pick up a trip to Hawaii? Anyway..I checked on the company and found that they are a damn appraisal management company. I sent the order back to the dude. Why cannot we get rid of that scum?
Because Dodd-Frank required a level of regulation that caused an expense for compliance the banks don’t want to take on. Because a group of lawyers told them they needed a firewall the size of the Grand Canyon when the original intent was more like a little river. Because now it’s become a big business for big data companies like Corelogic. Why has the larger national AMCs grown while the bank-owned have disappeared? It’s the threat of violation of regulatory laws that keep the AMCs in business. So either we work to get the rules changed or we still endure the same funny business…or we take over the AMC world and eliminate the bad players…or we go to a VA government-sponsored/run order system.
The days where the appraiser gets to talk to the loan officer directly are done. Doesn’t matter how much we were not to blame for 2008, the impression was we were. We have a PR issue.
One appraiser is reported to have smoking gun copies of emails along these lines. 2019 is going to be a very interesting year.
Hopefully, we’ll shortly get proof (written) that this fee setting arrangement has been ongoing between AMCs and lenders for a long time.
Honestly we have appraisers in our group that will work for basically nothing. I cannot change that nor can you. We have appraisers in our group that will do ANYTHING that they are told. I cannot change that nor can you. I have discovered over the years that NO ONE wants to pay money to find out our opinion of the value of a parcel of real estate without a reason. They want to borrow money, beat their spouse in a divorce or many other reasons. What I am trying to say is that THEY NEED US or they would not call us. Why in the world could an appraiser not have four times as much work as they could possibly complete?
Wayne,
Appraisers don’t have work because the general public does not understand what we do and why they should hire us. And big data companies have convinced the majority that a AVM report they can get for $18 is sufficient. The only place that doesn’t seem to fly is a court room, the IRS and/or your local tax collector and FNMA/FHA/VA until they figure out how to get around that. All in the name of consumer protection.
I am retired…BUT I have received an assignment for a commercial property in a city about 80 miles from me…This lender does NOT give one dam….this is ordered as an evaluation….12 inches in a foot, 3 feet in a yard….What is this property worth??? Please add a copy of your E&O…..We MUST be the most silly group of people on this planet! The lender ordered this by email…did not bother to confirm the fee or turn time. it is like they are at the drive-thru window at McDonalds wanting a Big mac with cheese….BUT if the VALUE estimate is not what they need then I am crazy…no matter what that value may be….Just a game…We are not professionals, we are just playing a stupid game!
I read where Nancy Pelosi is worth over 100 million….well you and I are idiots!…No doubt! I have goats in the pasture that are smarter than us! LOL
Don’t hate be because I am stupid…I mean BEAUTIFUL! Opps!
Here is an order request from ProTeck
Due Date: 11/12/2019
Fees collected by Vendor: $275.00
Services Requested: FHA UAD Single Family URAR (1004)
Please choose from one of the following actions:
ACCEPT ORDER DECLINE ORDER
Chances are another appraiser accepted this order. I do not even answer these request anymore, I just delete them.
Funny story: I don’t do AMC assignments, but about 3 years ago I receive an AMC email to appraise a 11,000 sq ft estate on 21 acres. Probably a $6 million+ value. The AMC stated a fee of $350 and 3-4 day turn time. My email reply, stated a fee of $4,000 and 4-5 weeks. The AMC called me to confirm, if my email had a typo and if I intended to state a fee of $400, LOL. I replied NO. I never received the assignment.
An update. Recently, I have done a few appraisals on high-value properties for an AMC I had never done work for before, but agreed to do the work because they accepted my higher fee. The appraisals were ordered for a refinance to get lower rates. These properties had just been purchased less than eighteen months before, and the loan was being done by the same lender. After completing the reports, it was brought to my attention that there were major discrepancies between my report and the reports they had on file from the purchase. One previous report had listed the home as a four-bedroom when in actuality its was a three-bedroom in utility and published permits. Evidently, the appraiser went with the sales agent’s deception of calling it a four-bedroom to support a higher list price. The appraisal I completed for another property appraised for lower than the purchase price less than eighteen months ago – in a stable market. The reviewer for this AMC (located in a midwestern city) called me up to discuss “my mistakes”. I asked the reviewer to send the comps that were used by the other appraiser at the time of purchase, and it turned out that most were more than 500+ sq.ft. larger in superior neighborhoods. I came away with the impression that this AMC has made it a habit to use the cheapest appraisers they can find and is now starting to see what kind of adverse effect it can have. Looks like there is the commonality between the AMC and their bottom feeder appraisers to “go along with the deal, so we can continue to get paid”!