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...

AMCs Deceptive Fee Skimming Exposed in Lawsuit Rocket Mortgage and the AMCs actively conceal this fee skimming from borrowers, never disclosing the proportion of the "appraisal fee"…
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…
The Appraisal Fee Lawsuit AMCs Can't Outrun The class action lawsuit filed against CrossCountry Mortgage and Class Valuation arrives at a moment when many in the appraisal…

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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...

ARCC Discussion Exposes GSEs Agenda to Reduce… Mark Calabria's discussion with ARCC revealed the GSEs' agenda to reduce "appraisal friction" by eliminating the role of professional appraisers…
FHFA's Appraisal Waivers Expansion The Federal Housing Finance Agency's (FHFA) recent push to expand the use of appraisal waivers represents a concerning and potentially…
GSE Exec Boasts Scheme to Slash Appraiser Numbers At a recent appraisal event, a GSE executive, after a few drinks, privately told his nearby colleagues that we suck…

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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...

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…
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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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...

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. …
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…
Exposing Predatory AMCs Exposing the inner workings of these predatory AMCs and their corrosive influence on the housing market. Cindy Chance's recent comments…

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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...

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…
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.…

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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...

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…
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. …

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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....

Full Transparency in Fee Disclosure Requirement to disclose appraisal fees: Uniform Settlement Statement SHALL include the AMC fee AND fee paid directly paid to the…
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…
Appraisal Fee Transparency Bill H.R.3619 has left the House and is now ready for consideration in the Senate. There are a number of key…

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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,...

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…
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…
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…

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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,...

Appraisal Fee Transparency Bill H.R.3619 has left the House and is now ready for consideration in the Senate. There are a number of key…
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…
Full Transparency in Fee Disclosure Requirement to disclose appraisal fees: Uniform Settlement Statement SHALL include the AMC fee AND fee paid directly paid to the…

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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...

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…
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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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...

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…
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…

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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…
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…
Eroding Consumer Protection Waiving appraisal requirements on residential homes could erode consumer protection, stall attempts to create diversity in the profession... The recent…

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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...

Faster Cheaper Appraisals! An appraiser shared the following with us. Vintage Mortgage Firm is offering faster cheaper appraisals. New Faster Cheaper Appraisals! Three…
$599 Waiver to Save the Borrower Money? The consumer is being fed yet another lie! Remember when we heard an appraisal waiver will save the borrower money?…
The Truth is They Don't Hire Professionals! Hybrid hucksters always argue “Why can’t trained professionals like brokers or insurance inspectors” perform the appraiser’s field inspection. The answer…

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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...

Open Letter to Taxpayers An Open Letter to Taxpayers Dear Ms; Mrs. & Mr. Taxpayer: In a recent article published by Housing Wire; authored…
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.…
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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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...

Working Paper Credibility Questioned NO REAL ESTATE APPRAISER IN THE COUNTRY IS ALLOWED TO MISS THE MARK BY 7.8% WITHOUT RISKING LOSS OF LICENSE!…
Proposal to End Appraisal Requirement Regulators' Proposal to End Appraisal Requirement on Some Home Sales of $400,000 and Below... The Federal Deposit Insurance Corp., the…
AMC Fees Exceeding Appraiser’s Fee AMC management fees exceeding the appraiser’s fee more frequently Over the past year, the AMC industry growth model – taken…

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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…
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…
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…

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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...

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…
Dear Representative, FNMA Has Gone Rogue! Dear representative, waiving/eliminating property appraisal for lending purposes is wanton recklessness. Fannie Mae’s decision to waive/eliminate property appraisal for lending…
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…

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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...

Fannie Mae Waiving Appraisals Property Inspection Waiver, getting back to the old days of fogging a mirror... Appraisers, Effective 12/10/16, FNMA will have a…
Software Provider Conflict of Interest(s)? ACI software & “restricted appraisals” that suffer from schizophrenia... It’s been awhile since I reviewed or researched influences affecting products…
Simply too BIG to Say No to... If they can’t even get their own PACE Pro form right, how are these alternative “valuation” providers going to get…

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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...

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 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.…
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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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...

Determining What to Charge for Appraisal Fees Charge too little and you can’t cover your expenses Have you ever asked yourself why gasoline prices seem to fluctuate…
FFIEC Requested Action on TRID The American Guild of Appraisers, Chapter 44, of the Office and Professional Employees International Union of the AFL-CIO (AGA, OPEIU/AFL-CIO)…
TRID Impact on Appraisal Fees Appraisers, The Consumer Finance Protection Bureau (CFPB) has mandated new residential mortgage application and disclosure procedures, which take effect Oct.…

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TRID - Appraisers Blogs

The AMCs: Coming Soon to a Lawsuit Near You

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Appraisal Industry Outlook Under Trump Administration

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The Great Debate on Appraisal Fees

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Lack of Fee Transparency: Exposing the AMC Exploitation

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Marcia Fudge leaving HUD!

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The Lack of Transparency in Appraiser Compensation

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TRID – Possible Changes by CFPB

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Do We Really Need a Rocket Mortgage?

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Appraisal Fee Transparency Bill Falls Short

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Fee Transparency, Pivotal Point for Appraisers

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No Shortage Exists

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Frivolous & Retaliatory 3rd Party Lawsuits

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Another Huckster Enters the Appraisal Arena

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AGA Objects De Minimis Increase Proposal

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Open Letter to Taxpayers

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Restraint of Trade Investigation

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Appraisal Alternatives

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Freddie Mac Criminal Aspects of Its Appraisal Free Mortgages

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Appraisers and Their Lack of Fees

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Consumer Involvement with Property Value

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