RESPA - Appraisers Blogs

The Great Debate on Appraisal Fees

Isaac Peck — Mon, 28 Oct 2024 12:30:09 +0000

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...

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…
Appraisal Regulation Compliance Council Exposes… The Appraisal Regulation Compliance Council published a detailed breakdown to the CFPB, which showed the median average AMC fee being…
AMCs Billing Scheme, Hidden Profits & Deceptive Practices Appraisers who do not agree to their hidden billing methods are excluded from the majority of the GSE lending marketplace…

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Appraisal Regulation Compliance Council Exposes Disturbing AMC Violations

AppraisersBlogs — Fri, 30 Aug 2024 12:30:34 +0000

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...

AMCs Violating TILA and C&R Fee Clauses Fellow Appraisers, the appraisal industry has been facing a major issue with AMCs violating the Truth in Lending Act (TILA)…
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…
AMCs Billing Scheme, Hidden Profits & Deceptive Practices Appraisers who do not agree to their hidden billing methods are excluded from the majority of the GSE lending marketplace…

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The Lack of Transparency in Appraiser Compensation

AppraisersBlogs — Wed, 06 Mar 2024 13:30:15 +0000

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 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. …
Appraisers Not to Disclose AMC Fee? An appraiser/reader sends me this text from an XOME appraisal request: Good Morning, The state of NY requires the appraiser…
AMCs Billing Scheme, Hidden Profits & Deceptive Practices Appraisers who do not agree to their hidden billing methods are excluded from the majority of the GSE lending marketplace…

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AMCs Take a Sizable Cut of the Appraisal Fee

Mark Skapinetz — Wed, 05 Oct 2022 12:30:29 +0000

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...

Uncovering Flaws in FHA Appraisal & Loan Review Process The story of this single mother's harrowing experience with a defective home purchase and HUD's negligent oversight exposes deep flaws…
The Town With No Bank: How Rural America Lost Its… For decades, we’ve been told that the problem is demand. That people don’t want to live in rural America anymore.…
Fannie Mae Filed a Complaint Against Me An appraiser shared the following with us which was posted on one of the appraisers’ groups. Fannie Mae filed a…

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Photos in Gated Communities Can be Tricky

Dustin Harris — Fri, 09 Oct 2020 12:30:36 +0000

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...

Promoting False "Racist Appraiser" Narrative Some Lenders promoting false "racist appraiser" narrative to optimize profits via AVMs Like most businesses lenders want to optimize their…
Security Bars Removal Law Debunks Alleged Racial… Complainant stated appraiser told them they should remove security bars from windows. Complainant stated this is evidence of "racist discrimination"...…
The Town With No Bank: How Rural America Lost Its… For decades, we’ve been told that the problem is demand. That people don’t want to live in rural America anymore.…

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Fee Transparency, Pivotal Point for Appraisers

Isaac Peck — Wed, 23 Oct 2019 12:30:10 +0000

…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...

First the Borrower Fee. Now the Appraiser… Two lawsuits place Class Valuation’s fee transparency and staff-appraiser compensation practices under federal scrutiny. Most appraisal disputes examine only one…
Uncovering Flaws in FHA Appraisal & Loan Review Process The story of this single mother's harrowing experience with a defective home purchase and HUD's negligent oversight exposes deep flaws…
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…

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Skipping Comp Photos, Suicidal Shortcuts

Michael Ford — Wed, 02 Oct 2019 12:30:17 +0000

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...

Appraisers, did you Shoot yourself in the Foot? When I explain the rules many of the appraisers start complaining: "An MLS photograph depicts the house at the time…
Can We Stop Taking Comp Photos? I personally do not think that appraisers should be required to take comp photos... First, before the hate mail starts…
First the Borrower Fee. Now the Appraiser… Two lawsuits place Class Valuation’s fee transparency and staff-appraiser compensation practices under federal scrutiny. Most appraisal disputes examine only one…

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Frivolous & Retaliatory 3rd Party Lawsuits

Michael Ford — Tue, 14 May 2019 12:30:47 +0000

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...

USPAP’s Typical Buyer Standard in the Fair Housing Era The Irreconcilable Conflict Between USPAP's Typical Buyer Standard and the Current Fair Housing Compliance Regime. Retain this document as a…
Appraiser Independence: What Does it Mean & Who Does… Why It Matters Appraiser independence is mandated by state and federal laws - not a professional courtesy. Every agent, broker,…
West Virginia Appraisal Board Scheme The Doomed Quest to Reform a corrupt West Virginia Licensing Board “Board members earn money working for a law firm…

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AGA Objects De Minimis Increase Proposal

Michael Ford — Thu, 10 Jan 2019 13:30:09 +0000

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...

Let's Get Rid of Appraisers. What Could Go Wrong? Why would regulators fundamentally weaken bank underwriting standards? Appraisers Warned The World In The Late 1990s And No One Listened.…
Open Letter to Taxpayers An Open Letter to Taxpayers Dear Ms; Mrs. & Mr. Taxpayer: In a recent article published by Housing Wire; authored…
Expert Wants to “Eliminate” Appraisers Mortgage Industry Expert Wants to “Eliminate” Appraisers – A Response The National Mortgage News website just published an interview with…

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Restraint of Trade Investigation

Michael Ford — Thu, 01 Jun 2017 12:30:23 +0000

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 .

You Are Not Alone - AGA How many appraisers do you know that are enthusiastic about the future of our profession? How many appraisers believe that…
Free Enterprise an Appraisal Myth? Is THAT free enterprise?I’m surprised anyone in the business today sees any minimum pricing proposal as being anti-free enterprise. Contrary…
Paying Too Much For Appraisals? Why am I paying more than TWICE the amount paid to the appraiser? I was recently charged/paid $750.00 to have…

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AMC Dangers to the Consumer

VaCAP Board — Wed, 15 Jul 2015 12:30:26 +0000

Appraisal Management Companies (AMC) are changing how our profession works. It’s important to know exactly how they are affecting the real estate process, especially if you are a home-owner, looking for real estate or are involved in another part of the property. Who does an Appraiser work for? An appraiser works for “The Client” named in the report who ultimately responsible for the appraiser’s compensation. It is important to realize that while a borrower may have paid a lender or third party the cost of the appraisal, “The client” remains the only party authorized to use the report. The appraiser...

VaCap Speaking out Regarding C&R Fees CUSTOMARY AND REASONABLE FEES When Dodd Frank was passed a few years ago there was much discussion as to what…
Day Laborers Needed...Inquire at any AMC Help Wanted - Day Laborers Needed .... Inquire at any AMC The Dodd Frank act requires the lender to be…
AMC vs Public Interest - VaCAP Advocacy Since the beginning, Federal Regulation of the industry was initiated to “protect the public. “ FIRREA, USPAP, HVCC, Dodd Frank…

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Court Won’t Unseal Files on Washington Mutual Appraisal Scheme

AppraisersBlogs — Tue, 16 Dec 2014 13:30:56 +0000

A federal judge said he will not unseal files related to an alleged appraisal rigging scheme that Washington Mutual launched in an effort to favor mortgage lenders just before the 2008 market crash, Courthouse News Service reported Dec. 3. The case involves a federal class action suit launched in 2008 in San Jose, California, by Felton Spears Jr. and Sidney Sholl who claimed that Washington Mutual, Lender’s Service Inc. and appraisal management firm First American eAppraiseIT colluded in 2006 to create inflated mortgage-loan appraisals that allowed the bank to sell aggregated security interests in the properties at inflated prices. At...

Top DEI Bosses Have a Problem - Diversity The ranks of the new DEI bosses at the financial institutions are no more diverse than the appraisers their institutions…
The New & Improved Fannie Mae “FRAUDULATOR 2.0” Originally known as Fannie Mae’s Collateral Underwriter (CU), and subsequently Collateral Underwriter 2.0 (CU-2)i this always dubious product of Fannie…
Is a Horde of Deadbeat Borrowers Again Walking Among Us? There are signs of a new horde of deadbeat borrowers, but the foreclosure filings are being delayed and masked by…

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Appraisal Management Company Sued in Consumer Class Action Complaint

Peter Christensen — Wed, 05 Nov 2014 13:30:40 +0000

A consumer class action complaint has been filed against a lender and its AMC relating to the subject matter of a prior CFPB investigation and settlement. Last August, the Consumer Financial Protection Bureau (CFPB) announced that it had taken action against Amerisave Mortgage Corporation, its affiliated AMC Novo Appraisal Management Company, and one of the owners of both companies Patrick Markert. Part of the CFPB’s action concerned alleged overcharging for appraisal services by the AMC and failure to disclose the AMC’s affiliation with the lender. Under a consent order, Amerisave and Novo agreed to pay $14.8 million in refunds to consumers and a $4.5 million...

The Town With No Bank: How Rural America Lost Its… For decades, we’ve been told that the problem is demand. That people don’t want to live in rural America anymore.…
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…
USPAP’s Typical Buyer Standard in the Fair Housing Era The Irreconcilable Conflict Between USPAP's Typical Buyer Standard and the Current Fair Housing Compliance Regime. Retain this document as a…

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HUD Blacklisting: Guilty Until Proven Innocent

Isaac Peck — Mon, 22 Sep 2014 12:30:21 +0000

HUD has been quietly blacklisting appraisers for years without due process Being on HUD’s FHA Appraiser Panel and performing FHA appraisals is an essential source of work for many appraisers. However, according to a recent legal brief filed by the National Association of Appraisers (NAA), HUD has been quietly blacklisting appraisers for years without due process. At the center of the case against HUD (U.S. Department of Housing and Urban Development) is Ken Taggart, an appraiser in Penn., who was removed from HUD’s roster in January 2010. Taggart says that his mortgage servicer, GMAC Mortgage, LLC, mistakenly forclosed on his...

Big Banks Blacklisting Appraiser Both Fannie and Freddie will now have their own blacklists and if you think getting off a bank’s blacklist is…
John Dingeman Reinstated from Chase "Black List" American Guild of Appraisers Member John Dingeman Reinstated from Chase "Black List" NEW YORK, Jan. 15, 2014 /PRNewswire-USNewswire/ -- After…
Blacklist: Appraisers Judged by Computers Blacklist of Appraisers - the End Is/Must Be Near: Advancements in the Art of Blacklisting If you are a real…

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Agencies AMC Rules Lack Guidance

AppraisersBlogs — Wed, 18 Jun 2014 12:30:12 +0000

Banking Agencies are Told Proposed AMC Rules Fall Short on Guidance In comments filed June 6 with several federal banking agencies, the American Society of Appraisers (ASA) and the National Association of Independent Fee Appraisers expressed our concerns that rules proposed to regulate appraisal management company (AMC) conduct lack sufficient detail to allow for effective implementation. Additionally, the organizations expressed concern that some provisions of the proposed rule depart from Congress’s intent when the enabling law was included in the Dodd-Frank Act, and could negatively affect the overall public policy goals. In the comment letter, ASA and NAIFA cover numerous...

Proposed Rule for AMCs Agencies Issue Proposed Rule on Minimum Requirements for Appraisal Management Companies WASHINGTON — Six agencies today issued a proposed rule…
Federal Register: AMC Final Rule AMC Regulation Rule Finally Published in the Federal Register Appraisers and others, On June 9, 2015, the Federal Register published…
Minimum Requirements for AMCs Proposed Federal Regulation of Appraisal Management Companies (Minimum Requirements for AMCs) I hear a lot from appraisers concerning their interactions…

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Where Did All the Good Appraisers Go?

Hamp Thomas — Fri, 02 May 2014 12:30:22 +0000

The good appraisers are leaving mortgage appraising as fast as they can. Thus far the housing industry has been applying “Band-Aid” solutions to the bigger real estate crisis. There are several problems going on at the same time, all contributing to the big picture, which is bleak to say the least. One true crisis in the real estate industry is an “information crisis.” This information problem, trickles down to appraisals, lenders, and ultimately, mortgage investors. Standardization, national guidelines, and disclosures are the only way back from this nightmare (i.e. the RESPA disclosure. One fee on the good faith estimate for...

Good Old Days of Appraising! Missing the Good Old DaysDoes anybody miss the good old days of having to deal with the mortgage broker? After…
Time to Bring Back Common Sense Appraiser No More, Think I'll be a Lawyer: it takes less time to get a law degree than to get…
Dear AMC, Goodbye... Why I'm Leaving Residential Appraisal - Dear AMC, Goodbye! The Law of Unintended Consequences is a law, like Murphy’s Law,…

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Mortgage Disclosure Rule Alters Appraisal Fee Reporting

AppraisersBlogs — Fri, 10 Jan 2014 12:30:09 +0000

The Appraisal Institute on Dec. 17 finalized its review of the Consumer Financial Protection Bureau’s 1,888-page final rule on Integrated Mortgage Disclosures under the Real Estate Settlement Procedures Act and the Truth in Lending Act, and noted several provisions that impact real estate appraisers and how appraisal fees are reported. The rule, which takes effect Aug. 1, 2015, mandates the use of two new disclosure forms, the Loan Estimate (which replaces both the Good Faith Estimate and the initial Truth in Lending Disclosure) and the Closing Disclosure (which replaces both the HUD-1 and the final Truth in Lending Disclosure). It...

USPAP’s Typical Buyer Standard in the Fair Housing Era The Irreconcilable Conflict Between USPAP's Typical Buyer Standard and the Current Fair Housing Compliance Regime. Retain this document as a…
The New & Improved Fannie Mae “FRAUDULATOR 2.0” Originally known as Fannie Mae’s Collateral Underwriter (CU), and subsequently Collateral Underwriter 2.0 (CU-2)i this always dubious product of Fannie…
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…

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To Disclose or Not to Disclose AMC Fees

AppraisersBlogs — Thu, 25 Oct 2012 12:30:03 +0000

To Disclose or not to Disclose AMC Fees… With the Consumer Financial Protection Bureau (“CFPB”) up and running, there are numerous regulatory issues still pending relating to the Dodd-Frank Act. The regulatory issues include appraisal independence rules, AMC fee disclosure, AMC registration, required physical property visit by appraisers in “higher risk” mortgages, HUD-1/RESPA Consumer Disclosure, and asset backed securities. Of particular note, the CFPB has proposed a new Consumer Disclosure form that is intended to replace the HUD-1 settlement statement. The proposed rule which was release for public until November, allows disclosure of appraisal management company fees, but does not...

USPAP’s Typical Buyer Standard in the Fair Housing Era The Irreconcilable Conflict Between USPAP's Typical Buyer Standard and the Current Fair Housing Compliance Regime. Retain this document as a…
The New & Improved Fannie Mae “FRAUDULATOR 2.0” Originally known as Fannie Mae’s Collateral Underwriter (CU), and subsequently Collateral Underwriter 2.0 (CU-2)i this always dubious product of Fannie…
It’s Time to Take Out the Junk: AMC Practices Exposed Appraisers have spent years carrying the weight of broken AMC practices, and this article pulls every one of those practices…

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NAIHP Exposes AMC Tax Evasion / RESPA Violations

AppraisersBlogs — Mon, 13 Feb 2012 12:00:25 +0000

AMCs violating RESPA NAIHP recently discovered many Appraisal Management Companies (AMC’s), are operating without authority in most states and have failed to pay state income tax. When businesses are formed, they are required to register with their Secretary of State, for authority to conduct business. That registration alerts the State Tax Department you exist and may be responsible for certain taxes. The same holds true if you operate outside your home state, according to Marc Savitt, NAIHP President. “Most AMC’s are only registered in a handful of states, but operate nationwide. If you’re not registered, you’re not paying taxes,” said...

HUD Secretary's Comments Evoke Folly of 1919 Sex Scandal Secretary Fudge launched into what sounded remarkably like discriminatory rhetoric: "The problem is who is in the appraisal industry. When…
It’s Time to Take Out the Junk: AMC Practices Exposed Appraisers have spent years carrying the weight of broken AMC practices, and this article pulls every one of those practices…
The Real Cause of the Home Value Gap Is the Income Gap Blaming appraisers for the income gap will never solve the real underlying problem... Blaming appraisers for the income gap is…

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RESPA - Appraisers Blogs

The Great Debate on Appraisal Fees

Related Posts:

Appraisal Regulation Compliance Council Exposes Disturbing AMC Violations

Related Posts:

The Lack of Transparency in Appraiser Compensation

Related Posts:

AMCs Take a Sizable Cut of the Appraisal Fee

Related Posts:

Photos in Gated Communities Can be Tricky

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Fee Transparency, Pivotal Point for Appraisers

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Skipping Comp Photos, Suicidal Shortcuts

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Frivolous & Retaliatory 3rd Party Lawsuits

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AGA Objects De Minimis Increase Proposal

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Restraint of Trade Investigation

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AMC Dangers to the Consumer

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Court Won’t Unseal Files on Washington Mutual Appraisal Scheme

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Appraisal Management Company Sued in Consumer Class Action Complaint

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HUD Blacklisting: Guilty Until Proven Innocent

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Agencies AMC Rules Lack Guidance

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Where Did All the Good Appraisers Go?

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Mortgage Disclosure Rule Alters Appraisal Fee Reporting

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To Disclose or Not to Disclose AMC Fees

Related Posts:

NAIHP Exposes AMC Tax Evasion / RESPA Violations

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