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’...
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. 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...
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 & 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...
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...
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...
The grand scheme of suing appraisers! Who Is Llano Financing Group? Who Is Carrington Capital Management? Why Are They Suing So Many Appraisers? Short Summary Update 8-17-15: Hundreds of appraisers are being sued by two entities that invest in suing appraisers for profit. At this time, the entity filing the most lawsuits against appraisers is Llano Financing Group, and most of the appraisals it is suing over were held by Impac Funding/Impac Mortgage. Impac is expressly assigning its claims and rights to sue appraisers to the investors (according to the court complaints). In the last three months, the investors have sued about 280 appraisers...
Appraisers, The Consumer Finance Protection Bureau (CFPB) has mandated new residential mortgage application and disclosure procedures, which take effect Oct. 3, 2015. Here’s a link to a brief article about this. When a consumer applies to a mortgage lender, the lender requests certain information from the consumer before the clock starts ticking in terms of ‘timing requirements’ on the consumer’s application. When the application is considered “complete”, the lender has 3 business days to provide the consumer with the Loan Estimate document. What’s of concern among lenders and appraisers is the speculated inability to change appraisal fees, which is disclosed...
Voice of Appraisal Podcast RE Coester vs. VREAB Lawsuit Folks, Phil Crawford with Voice of Appraisal has another great podcast about the appraisal profession and the recent lawsuit filed in Virginia against the Real Estate Appraiser Board (VREAB). This is probably the most important Voice of Appraisal show to date. In this “must listen” podcast, Phil discusses Coester lawsuit against VREAB and AMCs’ unsustainable business model. He does a stellar job with his analysis and recommendations of Coester vs. VREAB lawsuit. Phil, a fellow appraiser, who has become a catalyst for change in the appraisal profession, stated in his earlier...
