Tagged: AMC

FFIEC Requested Action on TRID - Imagecredit Flickr - Johannes Ahlmann 6

FFIEC Requested Action on TRID

The American Guild of Appraisers, Chapter 44, of the Office and Professional Employees International Union of the AFL-CIO (AGA, OPEIU/AFL-CIO) wishes to add its name to the attached letter on behalf of our professional appraiser members, and our thirteen million consumer members and their families, with the additional concerns: As written, TRID necessarily embeds an appraisal fee cap determined by third party service providers other than appraisers, within the initial consumer disclosure provided to prospective borrowers. The perception of these providers as to what constitutes “customary and reasonable fees” as required under Dodd-Frank is at odds with what appraisers consider to...

Don't Fence Me In - Physical Inspection 3

Don’t Fence Me In

We truly live in an incredible world. The age of information and technology has given us more freedom than at any other time in the history of mankind. Just in the last few years, the mobile office has become a reality in such a way that it would be nearly impossible for our clients to know much about our physical office at all. Since most of us have little to no walk-in traffic, running an appraisal office from a spare bedroom at home or even from the lanai of your Belizean condo is not out of the realm of possibility....

A Contrary Response to The Future of Valuation - Imagecredit Flickr - Simon Cunningham 6

A Contrary Response to The Future of Valuation

Recently an article appeared in WorkingRE about the Future of Valuation. The author is the President of a large and highly respected Appraiser  Peer and Educational Organization.  My own contrary response was either too lengthy, or deemed too critical of a big advertiser for publication in WorkingRE. I thank the hosts of this blog for granting the space. My concern with the author’s views starts with the description of our Real Estate Appraisal profession as ‘valuation.’ The concern is more than mere quibbling over semantics. Valuation is the phrase preferred by the Business Valuation community. They have long been dominated...

Free Enterprise an Appraisal Myth 40

Free Enterprise an Appraisal Myth?

Is THAT free enterprise? I’m surprised anyone in the business today sees any minimum pricing proposal as being anti-free enterprise. Contrary to popular belief we have not had free enterprise in the GSE appraisal process since HVCC first reared its ugly head. AMCs ‘telling’ us to pick a number from $250 to $350, or that ‘THEY pay’ $325 per 1004 is NOT free enterprise. I’m an old timer (1986) that was brought up on what used to be AIREA (now the AI) & SREA (now gone) positions that free enterprise and the Sherman Anti-Trust Act prohibited us from ‘even discussing’...

“Customary” & “Reasonable” Fees Exclusive Oxymorons 10

‘Customary’ & ‘Reasonable’ Fees – Oxymorons

If WE don’t set ‘reasonable’ minimums for ourselves, then others will do it for us (or to us). Fellow appraisers, Please read this draft proposal for minimum national appraiser fees. I appreciate those who believe no one other than themselves should set fees, and I concur. Except, in the real world of today someone (lenders and AMCs) are ALREADY SETTING your fees. If not directly, then through ruinous less than customary OR reasonable fee competition. I’m interested in your meaningful, constructive feedback as well as comment & discussion here. For those that insist ONLY regional fees are practical, this same system works...

It takes a “special” type of appraiser to work with AMCs 40

“Special” Type of Appraiser

It takes a “special” type of appraiser to work with AMCs. While inspecting a property I received a cell phone call from a lender wanting to add me to their panel. I was unable to discuss the matter at that time and requested that she send the information to my email. I received nine pages of application. The invitation starts out telling me how their AMC is a LEADER in the field (I never heard of them). They strive to assist all appraisers who are looking to maximize their time and quality. Their website allows them to monitor appraiser’s efficiency...

Appraisers Landmark $36M Settlement with BofA 7

Appraisers Landmark $36M Settlement with BofA

Editor’s Note: Besides being a bit of good news, this ruling could have implications for all appraisers working for AMCs. Appraisers Landmark $36 million Settlement with Bank of America for Failure to Pay Overtime Settlement Covers 365 Plaintiffs Who Served as Residential Real Estate Appraisers Oakland, CA – Today, employment and civil rights attorney Bryan Schwartz announced a settlement between Landsafe Appraisal Services, Inc., a subsidiary of Bank of America (NYSE: BAC) and 365 current and former employees working as residential real estate staff appraisers. The plaintiffs had sought damages for their misclassification as exempt from overtime, which left them...

Background Checks Issue for Appraisers - Imagecredit Flickr - Alan Levine 12

Background Checks Issue for Appraisers

Background checks & third party relationships Appraisers, One of the recent thorns in appraisers’ sides has been the issue of background checks. A key reason for this is the Office of the Controller of the Currency (OCC) bulletin, which outlines the management responsibility banks must take when dealing with ‘third parties. Third parties include the AMC’s banks use to ‘manage’ their appraisal orders, and vendor appraisers. The bulletin puts the fear of God into bank Board of Directors. Since water runs downhill, the banks are telling AMCs that they must improve how they ‘vet’ appraisers on their panels. Many AMC’s are...

Skewed Customary Fee Perceptions - Imagecredit Flickr - Quinn Dowbroski 14

Skewed “Customary” Fee Perceptions

I no longer care about “customary”. “Customary” in Dodd-Frank’s customary and reasonable is a negatively biased fee before state studies begin! We all know that the “C” part of C & R is supposed to represent the normal fee charged by most appraisers for similar work and conditions. Some AMC appraisers even know the “R” part is supposed to be an amount that is reasonable based upon ALL factors necessary for completion of the assignment in a USPAP compliant and professional manner. Unfortunately HVCC and the AMC havoc it wreaked has existed far too long for there to be a...

LSI Fees - Absolutely Criminal! 15

LSI Fees – Absolutely Criminal!

We used to do a lot of work for LSI back when they paid semi decent fees that were only about 10% below the competitive norm back around 1992. I think the norm was around $300 and they were paying $275+/-. In late 1992+/- they cut back to $235. We lost a few people but most stayed. Bear in mind the appraisers were being paid on a fee split. I think they got 50% of the firms fee. I was on salary for QC review and teaching work plus a split fee for field reviews. Back then it was much simpler to...

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