Tagged: appraisal fees

The Great Debate on Appraisal Fees 31

The Great Debate on Appraisal Fees

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...

Insights from CFPB's Public Comment Period 53

Insights from CFPB’s Public Comment Period

The comment period on the Consumer Financial Protection Bureau’s (CFPB) “Request for Information Regarding Fees Imposed in Residential Mortgage Transactions” concluded on August 2, 2024, with a total of 959 comments received. Upon reviewing some of these submissions, several noteworthy perspectives emerged regarding appraisal fees and the role of Appraisal Management Companies (AMCs). The National Association of REALTORS® (NAR) highlighted the lack of transparency surrounding AMC fees, which are often bundled together with the actual appraisal fee on the Closing Disclosure (CD). This opaque structure prevents consumers from understanding the true cost of the appraisal service and hinders their ability...

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...

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 Elephant In the Room: Fannie's Modernization Program 35

The Elephant In the Room: Fannie’s Modernization Program

The Elephant I refer to is simply this: Fannie Mae’s modernization program is going to put a lot of appraisers out of business. It’s all “lender centric”. It’s all about better, faster, cheaper, appraisals (with lots more data) for lenders. As an appraiser, all I see are sticks… no carrots. Nobody wants to talk about the Elephant in The Room. Post COVID 19, business was excellent; fees were high and we profited. High interest rates killed the market and most all of us now are not profiting. Losing money is not sustainable for any business and waiting for the next...

Mortgage Application Volume Nearing Historic Low 32

Mortgage Application Volume Nearing Historic Low

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...

AMC Engagement Letter: Do Not Include Your Invoice 17

AMC Engagement Letter: Appraisers Do Not Include Your Invoice

File the complaint against the AMC yourself OR Forward the engagement letter to VaCAP to file on your behalf.  At the recent Virginia Appraisal Board Meeting on Wednesday June 28th, a discussion occurred about Appraisal Management Companies prohibiting appraisers from including their invoices with the appraisal report. The overall consensus of the Board Members was this practice could be a violation of Virginia Appraisal Management Company Statute § 54.1-2022 B. “B. The appraisal management company shall not prohibit an appraiser from disclosing in the appraisal report the actual fees charged by an appraiser for appraisal services, and shall otherwise comply...

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...

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