Tagged: RESPA

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...

AMC / Appraisal / Appraisal Management Companies / Appraisal News / Appraisal Organizations / Appraisers News

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...

AMC / Appraisal / Appraisal Management Companies / Appraisal News / Appraisers News / CFPB

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...

AMC / Appraisal / Appraisal Management Companies / Appraisal News / Appraisal Subcommittee / Appraisers News

Appraisal Management Companies Take a Sizable Cut of the Appraisal Fee 97

AMCs Take a Sizable Cut of the Appraisal Fee

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...

AGA / AMC / Appraisal / Appraisal Management Companies / Appraisal News / Appraisal Organizations

Pictures in Private Neighborhoods Can be Tricky 11

Photos in Gated Communities Can be Tricky

Let’s talk about assignments in private neighborhoods, gated communities, or secure communities. Rich folks buy, sell, and refinance their homes, too, so they need appraisals. You have an assignment in a security community. There is security at the entrances, you must be on security’s authorized visitor list to get in, and your permission to enter this private community extends solely to visit your subject. So, here is the question: while inside this gated, secure community, do you also drive around and take photos of the comps? Now, even though you are reading this, I can see you looking at me...

Appraisal / Appraisal News / Appraisers News

Appraisal Fee Transparency Act of 2019: Pivotal Point for Appraisers 21

Fee Transparency, Pivotal Point for Appraisers

…appraisers may finally have a chance at making the goal of fee transparency a reality… Keep your eyes open, events are happening fast. Ever since the passage of the Home Valuation Code of Conduct (HVCC) in 2010 and the monumental rise of Appraisal Management Companies (AMCs), one of the main issues appraisers have pressed for is transparency for consumers in terms of the fee split between appraisers and AMCs. Specifically, how much of the actual “Appraisal Fee” being paid by the consumer goes to the licensed real estate professional and how much is withheld by the AMC “manager.” Now, over...

AI / AMC / Appraisal / Appraisal Institute / Appraisal Management Companies / Appraisal News

Time Saving Shortcuts Undermines Our Profession. Skip the Comp Photos 53

Skipping Comp Photos, Suicidal Shortcuts

I refuse to undermine my own profession by pretending that time saving shortcuts are always acceptable just because they are ‘more modern and progressive’. I know how long it takes to produce USPAP compliant, credible appraisal results. I charge accordingly for my time. I make no effort to compete on fees with half assed hybrids, evaluations, or single approach partially performed field work. Respectfully, neither should anyone else. Please stop undermining our own profession…. Recently The Appraiser Coach posted an article and links to a podcast suggesting its no longer necessary to photograph our comparable sales. I wrote a counter...

AGA / Appraisal / Appraisal News / Appraisal Organizations / Appraisers News / Fannie Mae - Freddie Mac

Protecting Appraisers Against Frivolous & Retaliatory 3rd Party Lawsuits 6

Frivolous & Retaliatory 3rd Party Lawsuits

Appraisers are routinely coerced & intimidated by third parties to violate their independence and integrity… Honorable Committee Members: We are writing to add our voice to that of the Massachusetts Board of Real Estate Appraisers (MBREA is a State Coalition of professional real estate appraisers) in support of each of the above bills. The American Guild of Appraisers is a Guild within the Office Professional Employees International Union (OPEIU) of the AFL-CIO, representing the appraisal and real estate related financial consumer / taxpayer interests of over twelve and a half million AFL-CIO Family Union & Guild Members; their families, retirees...

AGA / AMC / Appraisal / Appraisal Management Companies / Appraisal News / Appraisal Organizations

AGA Objects De Minimis Increase Proposal - It is Time to Call out the Liars 40

AGA Objects De Minimis Increase Proposal

We object to the proposal to increase the de minimis threshold at which no appraisal is required… Sirs: The American Guild of Appraisers (AGA), of the Office Professional Employees International Union (#44 OPEIU) of the AFL-CIO represents the members and extended family and retirees, taxpayer and consumer real estate appraisal interests of nearly Twelve and a half million citizens and voters. We object to the proposal to increase the de minimis threshold at which no appraisal is required from $250,000 to $400,000. Respectfully, if anything is done with it at all, lowering it to a range not to exceed $100,000...

AGA / AMC / Appraisal / Appraisal Management Companies / Appraisal News / Appraisal Organizations

Suppression of Appraisal Service Free Trade & Fair Price Competition 25

Restraint of Trade Investigation

I am heartened that the Federal Trade Commission has recognized the need to assure that appraisal “…consumers deserve to benefit from a free market where those fees are set by competition.” It appears that your complaint may have been instigated by the very special interests that are most responsible for suppression of appraisal service free trade and fair price competition in America today. By that I am referring to the entities broadly described as Appraisal Management Companies (AMCs), and in this specific complaint – the Federal National Mortgage Association, also known as Fannie Mae and/or FNMA .

AGA / AMC / Appraisal / Appraisal Management Companies / Appraisal News / Appraisal Organizations

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