Appraisal news for real estate appraisers and real estate professionals regarding Customary & Reasonable Fees. News relating to the Appraisal Industry.
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...
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...
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...
Fellow Appraisers, the appraisal industry has been facing a major issue with AMCs violating the Truth in Lending Act (TILA) and the Customary and Reasonable fee clauses. This has not only caused harm to consumers but also to appraisers who are struggling to make a living. Despite efforts to bring this issue to light, it has been largely hidden from the public and regulators. However, it is time to change that and reveal the truth about what is really happening. To do so, we need to gather more data and evidence to establish a pattern of violations for these bids...
It’s a Great Time to Leave the Appraisal Profession. I can hear the chorus of my fellow appraisers rising up in disagreement with me. I envision many of them screaming, “But I love being an appraiser”! Yeah, I hear you. I loved being an appraiser too. Let’s not consider what we were but what they want us to become. First, ask yourself if you are still making a livable wage. I’m not and instead of blaming myself, I started running the numbers. In, my high value market, 18% of the solds were cash sales. No appraisal required on those! Values...
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...
It still proves my point: Appraisal Management Companies take a sizable Cut of the appraisal fee… It was March 28th, 2018 that I wrote my very first blog post entitled “What’s not in your wallet?” where I went into great detail about how Appraisal Management Companies or AMCs get paid and how the consumer is not aware of the fact that the AMC is taking much of the fee while finding the cheapest and fastest appraiser. In that blog post, I gave many examples of the abuse appraisers and consumers are absorbing by these Appraisal Management Companies. How one borrower...
Why would I bother taking on the added risk of an inconvenient process? Where is my incentive again? As an appraiser, I have to ask (seriously) why should I care if the profession has a shortage of skilled appraisers? Logic dictates that If there is a shortage, then I will remain busy. Even if waivers (another ruse to eliminate appraisal work) increase, I’ll be busier with fewer appraisers. Especially with so many of them “trained” under PAVE or PAREA programs. If there is an adequate supply of appraisers, then users of appraisals will continue to seek cheaper alternatives from them...
VaCAP has learned the Georgia Real Estate Appraisal Board is considering rescinding rule 539-1-.23. This rule is the customary and reasonable fee requirement to appraisers from appraisal management companies. The matter will be decided at a 9:30 AM Sunday July 17, 2022 meeting. From the Georgia Real Estate Commission and Appraisal Board: RULE 539-1-.23 Appraisal Management Companies Purpose: In light of the recent decision and order In the Matter of Louisiana Real Estate Appraisers Board Before the Federal Trade Commission of the United States and to avoid even the appearance of anticompetitive conduct or the unreasonable restraint of price competition...
The FTC has cost the appraisal profession dearly in their pursuit of the State of Louisiana. This entire episode has been entirely misguided… The FTC’s time SHOULD have been spent investigating the AMC trade group known as REVAA to find TRULY non-competitive practices… The FTC is asking for public comments on the consent decree by the Louisiana Real Estate Appraisal Board. The time line to comment is short and ends on July 22, 2021. VaCAP asks each of you to take a few minutes and read the consent decree as well as the analysis provided by the FTC before commenting....
