TRID - Appraisers Blogs

The AMCs: Coming Soon to a Lawsuit Near You

AppraisersBlogs — Tue, 20 Jan 2026 13:30:22 +0000

The AMCs built an entire system on silence, and now the quiet parts are being said out loud. For years, the mortgage industry has insisted that appraisal management companies are the guardians of independence, the compliance buffer that keeps lenders and appraisers at a safe distance. Yet 2025 has delivered a storyline that feels more like satire than industry narrative. Borrowers are suing, judges are listening, and the AMC business model is beginning to look less like a safeguard and more like a very expensive middleman with a very opaque invoice. The first shock came from California, where the Timmins...

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Appraisal Industry Outlook Under Trump Administration

AppraisersBlogs — Mon, 06 Jan 2025 13:30:04 +0000

In a recent article, John D. Russell, JD explored the potential impact of the new Trump administration on the appraisal industry. With Republicans set to control the legislative process, Russell analyzed various documents and comments to distill expectations for how appraisal-related issues may be handled going forward. He noted that the Trump administration’s efforts will likely reflect much of the Project 2025 platform, and that its approach to the GSEs and FHFA in the first term could mirror that of the previous administration. Late first-term efforts on housing finance reform may also provide insight into second term priorities. Regarding the...

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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...

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Lack of Fee Transparency: Exposing the AMC Exploitation

Desiree Mehbod — Wed, 31 Jul 2024 12:30:07 +0000

By keeping the borrower in the dark about the true cost of the appraisal, the AMCs are able to charge exorbitant prices and pocket the difference (as shown in Figures 1 through 10), exploiting the consumer’s lack of knowledge. Thank you for the opportunity to comment on the Consumer Financial Protection Bureau’s Request for Information on Fees Imposed in Residential Mortgage Transactions. The growth of Appraisal Management Companies (AMCs) in the wake of the 2008 financial crisis was driven by a well-intentioned but ultimately misguided belief that they could help “ensure the integrity and independence” of property valuations. The reasoning...

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Marcia Fudge leaving HUD!

Dave Towne — Tue, 12 Mar 2024 12:30:23 +0000

Marcia Fudge is also the current co-chairperson of the PAVE Task Force Committee, so that group’s philosophy may also be modified with her resignation. I read a number of web provided publications oriented to our appraisal work, and lending. This popped into my email yesterday from Inside Mortgage Finance Publications: “As IMFnews went to press Monday, Marcia Fudge announced that she will step down as secretary of the Department of Housing and Urban Development, effective March 22. A Biden appointee, Fudge, 71, did not provide a specific reason…” USA Today: “Fudge vows not to run again “Don’t look for me...

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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...

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TRID – Possible Changes by CFPB

Dave Towne — Mon, 25 Nov 2019 13:30:07 +0000

For appraisers and lenders, a key sticking point is the ‘appraisal fee’ has been hard-fixed, quoted up front, and difficult to change, at the time the assignment is given to the appraiser… Appraisers / Lenders, the Bureau of Consumer Financial Protection (CFPB) has opened a comment period soliciting written comments on the current TILA-RESPA Integrated Disclosure (TRID) process applying to consumer mortgage loans. Comments can be submitted to the following addresses, until Jan. 21, 2020. You may submit comments, identified by Docket No. CFPB-2019-0055, by any of the following methods: Federal eRulemaking Portal: http://www.regulations.gov. Follow the instructions for submitting comments....

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Do We Really Need a Rocket Mortgage?

Frederick E Rossiter — Tue, 12 Nov 2019 13:30:57 +0000

Do we really need a “Rocket Mortgage“? “Rocket Approvals” are nice but certainly not “Rocket Closings”. The home buying process is not a race. It’s not Road Runner and Wile E Coyote racing to the closing table. It takes time! The Need for Speed How quickly do your buyers and sellers want to close on the home they just bought? Two weeks? Four, six, eight weeks? When you wrote the contract, and filled in the “drop dead dates” how much time did you allow for the Title deadlines, the Owners’ Association deadlines, the Seller’s Property Disclosure deadlines, the Loan and Credit deadlines,...

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Appraisal Fee Transparency Bill Falls Short

Michael Ford — Thu, 24 Oct 2019 12:30:33 +0000

No system that continues to allow (or limit) defining appraisal complexity to the lender or AMC will ever achieve reasonable, or fair compensation for the appraiser…. We need to do much better than “half a loaf” in our appraisal legislative efforts. Especially when that half loaf does no more than enshrine continued price-fixing by lenders; with the support & blessing of REVAA… WorkingRE published news of recent House of Representatives action. The Bill addresses consumer disclosure of AMC fees among other issues. While the American Guild of Appraisers applauds the efforts of those that worked in good faith on this,...

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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...

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No Shortage Exists

Michael Ford — Fri, 28 Jun 2019 12:30:51 +0000

No shortage exists other than too few appraisers willing to work for drastically discounted fees that would also be willing to overlook the complexities of rural appraising in their completion time estimates. Nowhere in the ND proposal is there an assurance that in return for waivers, consumers would not be charged one dime for appraisal or appraisal related AVM fees. “Rising costs” is a deceptive claim to hide bankers desires to usurp appraisal fees for themselves. Perhaps they would call them evaluation fees to warrant charging $600 to $1,500+ for 30 second AVM analysis fees. Dear Mr. Park: RE: Appraisal...

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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...

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Another Huckster Enters the Appraisal Arena

Michael Ford — Thu, 28 Mar 2019 12:30:55 +0000

Yet another third party huckster has entered into the real estate appraiser and appraisal arena. It’s that time again! Yet another third party huckster has entered into the real estate appraiser and appraisal arena. Apparently motivated by pure altruism. We identified a need in the marketplace to address a common problem that lenders are regularly challenged with in providing accurate appraisal quotes and then ensuring pricing on the Loan Estimate is consistent and compliant,” stated Vladimir Bien-Aime, president and CEO at Global DMS. (I LOVE this guy, he writes like me!) Global DMS Launches SnapVal to Provide Instant, Accurate, Guaranteed...

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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...

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Open Letter to Taxpayers

Michael Ford — Mon, 26 Nov 2018 13:30:56 +0000

An Open Letter to Taxpayers Dear Ms; Mrs. & Mr. Taxpayer: In a recent article published by Housing Wire; authored by Ben Lane (November 20, 2018) it was reported that our federal “regulators” are at it again. “At what?” One might ask. Facilitation of increased LOAN FRAUD & consumer deception with Taxpayers yet again left holding the bag. Click here for the article Back in 1994 (actually it started in 1989-91 when FIRREA was being drafted) the Fed agreed that the loan threshold for banks when an appraisal of real estate would not be required was $250,000. That was roughly...

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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 .

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Appraisal Alternatives

IDFPR Board — Mon, 09 Jan 2017 13:30:00 +0000

Computers eliminating “boots on the ground” residential appraisers. An historian once quipped, “I cannot predict the future, but give me six months and I’ll tell you why it was inevitable.” Residential appraisers who work in the mortgage arena began to experience the sea change when UAD arrived amongst much fanfare in September of 2011. Years of portals, hard-stops, and overrides have settled into an uneasy routine. We’ve already seen changes to closing docs as a result of TRID (TILA RESPA Integrated Disclosures). That adventure began in November 2013. Washington DC, never content to maintain any level of consistency has already...

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Freddie Mac Criminal Aspects of Its Appraisal Free Mortgages

Michael Ford — Mon, 14 Nov 2016 13:30:23 +0000

Freddie Mac is opening itself up to over 150,000± potential individual lawsuits… This is a response from Mike Ford to Kenneth Harney’s article, “Freddie Mac planning appraisal-free mortgages”. I represent the American Guild of Appraisers, #44OPEIU, AFL-CIO, and the real estate appraisal-related consumer and taxpayer interests of our more than fifteen million± AFL-CIO members, retirees and their families. I’m prompted to write this open letter regarding your recent well written & researched article, titled “Freddie Mac planning appraisal free mortgages”. Regrettably, it was too brief to cover several additional critical aspects of the issue, but I assume the Chicago Tribune’s...

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Appraisers and Their Lack of Fees

Guest Author — Mon, 14 Dec 2015 13:30:20 +0000

I feel it’s only prudent to put my ten cents, or more, in on the subject of actual cost, versus paid fees for appraisals After an overwhelming outpouring of response from appraisers all over the country, I am compelled to write a follow up article to “Appraisals and The Real Cost of Doing Business.” I must stress that my original intent was to highlight the ever increasing cost in all aspects of our industry, passed on to our clients, due for the most part to increased compliance requirements, additional staffing required to monitor said compliance, Dodd Frank rules, HVCC, TRID...

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Consumer Involvement with Property Value

Dave Towne — Fri, 11 Dec 2015 13:30:49 +0000

“Help” the consumer determine a value Appraisers, There is a little known provision in the new TRID mortgage loan application process that may become a future issue for appraisers, especially when the loan is for a Refinance. This is what the Loan Estimate, provided by the lender, requires the CONSUMER to do: You (the lender) must provide a Loan Estimate to the consumer, either by delivering by hand or placing in the mail, no later than three business days of the receipt of an application. An application is considered received when the consumer provides the following information: Consumer’s name, Consumer’s...

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