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...
At a recent appraisal event, a GSE executive, after a few drinks, privately told his nearby colleagues that we suck as an industry. Last year, Phil Crawford and I reported on GSE efforts to send unsigned complaints to state boards at scale. Appraisers had no recourse but to defend themselves from the state boards without knowing who their accusers were. The public pressure became real, and the GSEs backed off from their anonymous letter-sending campaign (see Cosmic Cobra Guy’s reference). The exercise showed how little they think of us as professionals because it’s easier to generate AVMs by pressing a...
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...
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...
Some of you appraiser in California may not realize there is a new law, AB-5, which goes into effect on 1/1/2020, less than 60 days from now that will have a significant effect on the working relationship between appraisers and AMCs. Most appraisers work as Independent Contractors when working with AMCs. However, this will most likely change under this new law, AB-5, as of the first of the year. Most engagement letters or other instructions from AMCs to appraisers are in conflict with this new law as it pertains to the use of Independent Contractors. Under most of these agreements...
When I explain the rules many of the appraisers start complaining: “An MLS photograph depicts the house at the time it sold so it’s more accurate than my photograph would be”… There’s a lot of yelling and screaming about bifurcated appraisals. Unfortunately, appraisers may have shot themselves in the foot when it comes to this issue. Allow me to provide an analogy to help explain the issue. I’m not sure if this happens in other areas of the country but in Seattle there is a strange “left leaning” way they do things: State and Federal governments perform numerous traffic studies, to...
…producing credible real estate appraisal reports… Is it any wonder that The Appraisal Foundation has lost nearly all credibility as America’s self-proclaimed foremost authority on appraisal matters? I humbly submit their most recent offering. Excerpt from current ASB Q&A: “2018-19 USPAP Q&A Issue Date: March 29, 2018 The Appraisal Standards Board (ASB) of The Appraisal Foundation develops, interprets, and amends the Uniform Standards of Professional Appraisal Practice (USPAP) on behalf of appraisers and users of appraisal services. The USPAP Q&A is a form of guidance issued by the ASB to respond to questions raised by appraisers, enforcement officials, users of appraisal...
There is no shortage of appraisers, only appraisers willing to work for Appraisal Management Companies, but there will be a shortage if the current toxic business climate does not change. The AMC business model is based on lies that hurt the consumer and your constituents. There are many voices that have agendas to reduce the qualifications to become a Real Estate appraiser, whether it be a Licensed Appraiser, Certified Residential Appraiser or a Certified General Appraiser. There are also voices that would like the requirements of an appraisal by a person licensed by the state to be waived as there is a...
AI all but abandoned the residential appraiser… I have been a member of the Appraisal Institute (AI) for many years and the organization has always been tilted toward the Certified General Appraiser. I am Certified General and recognized this long ago. I think the education of the AI is the best with no comparison for both residential and commercial and their publications are second to none. The AI has long neglected the residential appraisers as they sent in their $300 per year. The AI completely dropped the ball starting in 2007 when the crash began. The Appraisal Management Company (AMC)...
