Tagged: appraisal fee

Appraisal Regulation Compliance Council Exposes Disturbing AMC Violations 97

Appraisal Regulation Compliance Council Exposes Disturbing AMC Violations

The Appraisal Regulation Compliance Council published a detailed breakdown to the CFPB, which showed the median average AMC fee being charged to borrowers amounted to a staggering 65% of the total appraisal fee, with one AMC extracting as much as 84% in pure profit. The Appraisal Regulation Compliance Council (ARCC) is a crucial non-profit organization that specializes in providing fact-based research and expertise on the complex web of appraisal regulations and compliance issues. Driven by a non-partisan mission, ARCC has spent the last two years diligently collecting, vetting, and organizing comprehensive data on lender appraisals conducted by Appraisal Management Companies...

Lack of Fee Transparency: Exposing the AMC Exploitation 71

Lack of Fee Transparency: Exposing the AMC Exploitation

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...

Gov't-Indulged Middlemen Are Wrong RX for Battered Borrowers, The Infirm 14

Gov’t-Indulged Middlemen Are Wrong RX for Battered Borrowers, The Infirm

The U.S. government impoverishes homebuyers as it does the chronically ill – by promoting the use of middlemen who prey upon them. A cadre of such middlemen was created decades ago as a firewall between Big Pharma, the insurance companies and the pharmacy chains. Called “pharmacy benefit managers,” they were to negotiate drug prices, streamline distribution and manage lists of prescription drugs covered by insurance plans. But since the government has gone whole-hog into health care under the Affordable Care Act and into drug-price controls under the Inflation Reduction Act, things have gotten crazy at the slop trough. Today, according...

CFPB | Bureau Crackdown: Unfair Practices Hurting Consumers 23

CFPB Crackdown: Unfair Practices Hurting Consumers

Bureau is currently investigating various fees associated with obtaining a loan, with the goal of identifying any that may be particularly burdensome or concerning for borrowers. As we all know many AMCs are not paying Customary & Reasonable fee as required by TILA. They have consistently pushed down the pay of Appraisers while making undisclosed profit off consumers and prioritizing cheapest and fastest over quality and competency. The CFPB has been in communication with individuals behind the scenes and are concerned with what has been shown enough to include AMCs in their data collection process. Now is the time to...

Appraisal Fees & Value: Lessons from Picasso & Steinmetz 26

Appraisal Fees & Value: Lessons from Picasso & Steinmetz

Picasso answered “$5,000 madam.” “But it only took you five minutes.” “No, madam, it took me my whole life.”  The Appraisal Institute has been a source of frustration and criticism within the appraisal profession for quite some time. I must admit that I have also expressed my dissatisfaction with them. Nevertheless, I must acknowledge that the new CEO, Cindy Chance, appears to be a positive change and is making some valuable points about our profession from her new position. In particular, she recently discussed appraisal fees in a piece she wrote. In this excerpt, she shares two stories that provide...

The Lack of Transparency in Appraiser Compensation 20

The Lack of Transparency in Appraiser Compensation

The current system of bundling appraiser compensation with third-party fees can lead to confusion and frustration for both appraisers and consumers.  In their letter to the ASC, NAR highlighted the importance of appropriate compensation for appraisers. They stated that fair and reasonable compensation is critical to attracting and retaining high-quality appraisers, as well as allowing them to invest in their skills and education. However, the current system lacks transparency when it comes to reporting appraiser compensation. The issue lies in the TILA-RESPA Integrated Disclosures (TRID) form, which requires an aggregate appraisal fee to be reported. This means that the fee...

AMCs Billing Scheme, Hidden Profits & Deceptive Practices 82

AMCs Billing Scheme, Hidden Profits & Deceptive Practices

Appraisers who do not agree to their hidden billing methods are excluded from the majority of the GSE lending marketplace for appraisal orders.  Appraisal Management Companies (AMC’s) do not pass on cost savings for reduced appraisal services to consumers. Instead, they keep the savings for themselves without disclosing the amount to the consumer or the appraiser. What should have been cost savings for the consumer are pocketed by the AMC in secret. This is considered a junk fee or unearned fee billing scheme under current law. Appraisers who participate in this system are in violation of The Management Rule of...

NAR Concerns and Survey on Property Data Collectors 12

NAR Concerns & Survey on Property Data Collectors

NAR is conducting a survey and wants to know if you have any concerns regarding property data collectors, if the appraisal fees are higher since the involvement of data collectors, if borrowers are made aware of a fee for the appraisal and a separate AMC fee or were the fees bundled, if the property data collector gave the impression that they were the appraiser, whether you have any safety and privacy concerns with the data collection process, quality of data collected and whether they need to be licensed…  In a letter to the Federal Housing Finance Agency (FHFA) regarding appraisal...

AMC Fee Impact on Appraisal Fee 78

AMC Fee Impact on Appraisal Fee

While the borrower was charged $695 for the appraisal, the appraiser was only paid $301. The AMC fee was $394.  We often hear complaints from GSEs and lenders that appraisal fees are too high, hence the push for modernization. Yet they fail to acknowledge that this is due to an overly bloated middleman – the appraisal management company (AMC). As a consumer, you should be aware of the potential for being fleeced on appraisal fees. It’s possible that you could be paying more than double what the appraiser is receiving for actually doing the work, with the excess going to...

Average AMC Appraisal Fee 2021 vs 2022 134

Average AMC Appraisal Fee to the Appraiser

Average AMC appraisal fee to the appraiser: AMCs are taking far more of the borrower-paid fee this year than they did last year.  Appraisers, I recently sent out a message asking appraisers to send me three data points comparing borrower-paid appraisal cost, and average AMC paid assignment fees in October, November 2021 and the same months in 2022 – for SFR assignments. My intent was to provide actual useful AMC-paid fee data compared to what the borrower pays for ‘the appraisal’, without revealing specific fees in any particular location. Replies to that message were much less than I expected, and only...

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