She included several different fee split examples indicating AMCs retained as much as 70 percent of the total appraisal fee paid by the borrower, which prompted her to stop working with AMCs because of the lack of transparency. The appraisal industry is abuzz with a discussion about appraisal fees. The Consumer Financial Protection Bureau (CFPB) recently issued a Request for Information Regarding Fees Imposed in Residential Mortgage Transactions [Docket No. CFPB-2024-0021] in which it solicited feedback from the public and industry stakeholders on the fees charged to consumers by mortgage providers and related settlement services. The CFPB framed it as...
Alarmed by predatory practices among AMCs, a peer has drafted letters urging appraisers to call on state authorities to address unfair AMC conduct and potential regulatory violations. As appraisers, we have faced an ongoing challenge with Appraisal Management Companies (AMCs) offering fees that are well below the customary and reasonable rates for standard appraisal assignments. This practice has created a troubling trend of “bid wars” where AMCs pit appraisers against one another, driving down fees to unacceptably low levels. In response to this issue, a peer has provided two draft letters that can be easily modified and used by other...
By keeping the borrower in the dark about the true cost of the appraisal, the AMCs are able to charge exorbitant prices and pocket the difference (as shown in Figures 1 through 10), exploiting the consumer’s lack of knowledge. Thank you for the opportunity to comment on the Consumer Financial Protection Bureau’s Request for Information on Fees Imposed in Residential Mortgage Transactions. The growth of Appraisal Management Companies (AMCs) in the wake of the 2008 financial crisis was driven by a well-intentioned but ultimately misguided belief that they could help “ensure the integrity and independence” of property valuations. The reasoning...
Climbing out of that black hole is nearly impossible. It’s one reason why many appraisers are vacating mortgage lending appraisal assignments. This “discrimination settlement” hit the fan last week in a news feed I get. Another appraiser (in CA) settles a discrimination complaint: Oakland homeowner settles with appraiser, lender after $300,000 lowball appraisal The entire case is based on allegations by the homeowner, who had decided the value of the home was more than the appraised amount, before the appraisal was done. But when one reads through the story, one has to question whether the appraiser truly was biased against...
Appraisers, it seems this past year has been like furiously paddling against a giant iceberg containing frozen lending assignments in the North Atlantic ocean while in a rowboat with one paddle! The entire 2023 has been one chilling episode in terms of mortgage lending appraisal assignments for appraisers. While it’s too soon to tell for sure, a giant sea-going tug boat with high horsepower diesel engines powering twin propellers mounted on azipods has arrived on the scene to help direct and push that iceberg into warmer waters, releasing a flood of more assignments! I read lots of ‘stuff’ relating to...
As long as the new normal is reporting the appraiser when you don’t like the value continues, why bother? In today’s new and unimproved appraisal atmosphere, any appraiser that does not “hit the number” is open to detrimental consequences. Buyers, Sellers, & Refinancers – The U.S. Government from the top down have provided the media and the public in general with so much toxic misinformation and encouragement that any appraiser doing their job, a job that can lead to lower values than expected, can now be turned to HUD itself, or a state appraisal board for racial bias. So, why...
Appraisers, I’m almost reluctant to distribute this article, but the reality is what it is. Per the Mortgage Bankers Association (MBA), the loan application volume is at another low point in our history. The article in Mortgage News Daily titled “Mortgage Application Volume at Lowest Levels Since 1996” in this link provides context. For a related perspective, the article contains a graph, which can be expanded to show mortgage rates and application volume for decades. The brown line in the graph shows 30 year mortgage rates – since early 1971. The light blue indicates the loan application volume, which corresponds...
More and more appraisers are retiring every day. Aside from that more and more are changing to lower liability careers. Eventually, the opportunists who have been promoting the scam of racial discrimination by appraisers such as career politicians, and ‘anti-discrimination’ software hucksters like Black Knight will be shown to be what they truly are. Recently, a highly respected appraiser who is also a senior designated member of a well-known national professional peer association, wrote an article about a new proposed law in New York ostensibly targeting New York appraisers. Mr. Bagott’s article had an unusual amount of hyperbole within it...
Appraisers, something – comparing and contrasting – dawned on me last week, after reading another news release titled “Dean Kelker: Appraisal Modernization is Starting to Gain Momentum“, which is basically pushing an “Enterprise” singular ‘agenda’ of valuation speed regardless of accuracy. Under the banner of “modernization.” VA does not demand appraisers complete assigned appraisal assignments extraordinarily quickly. They give appraisers 7 – 10 days (depending on location) to submit the report after assignment. VA expects good quality and accurate information. FHA/USDA/ONAP also expects appraisal accuracy using an inspection protocol that many appraisers object to, and some choose not to do...
I gave this ‘opportunity’ further critical analysis in terms of time spent versus the fee income potential. Appraisers, I’d like to disclose a personal ‘opportunity’ that was presented to me last fall, early winter. A company with AMC roots was, or is, recruiting people to become “property inspectors” with the resulting reports potentially fed to other appraisers who do HYBRID, or maybe even DESKTOP reports. The GSEs never intended the DESKTOP report to incorporate separate ‘property inspections’ from a hired third party, but that’s been the evolution because they just look the other way. Last fall, due to the slowdown...
