The AMCs: Coming Soon to a Lawsuit Near You

by AppraisersBlogs · Published January 20, 2026 · Updated January 20, 2026

The AMCs: Coming Soon to a Lawsuit Near You 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 class action accused Clear Capital, Core Valuation Management, and Rocket Mortgage of charging borrowers appraisal fees that bore little resemblance to what the appraiser was actually paid. The complaint did not rely on speculation. It cited research submitted to the CFPB by the Appraisal Regulation Compliance Council (ARCC), showing that Clear Capital retained between 64 percent and 84 percent of sampled appraisal fees. For an industry that has spent years insisting that AMCs simply coordinate and facilitate, the numbers were difficult to explain away.

The defendants responded with a familiar argument. TRID allows bundled fees, so the disclosures could not be deceptive. But when the court issued its ruling on May 19, 2025, that argument did not carry the day. The judge allowed the core claims to proceed, including unfair business practices, fraudulent business practices, and unjust enrichment. The ruling did not announce a sweeping legal principle in a single sentence, but the effect was unmistakable. If TRID compliance automatically shielded lenders and AMCs from state law deception claims, the court would have dismissed the case. It did not. The lawsuit is now moving into discovery, where fee splits, engagement letters, and AMC retention rates will finally be examined. For AMCs, this is the moment when the lights dim and the soundtrack shifts.

Then came Florida. On December 16, 2025, a second class action was filed, this time naming Appraisal Nation LLC, AMC Links LLC, and United Wholesale Mortgage LLC. The allegations mirror Timmins almost exactly. Borrowers paid between $450 and more than $1,000 for an appraisal, the AMCs paid the appraiser only a fraction, and the remainder was quietly retained as an undisclosed management fee. Attorney Peter Christensen summarized the issue on LinkedIn, noting that the complaint alleges borrowers are stuck paying the AMC the lender selects, without any ability to choose an AMC or negotiate the AMC’s fees. It is a market failure presented as a service.

The Florida lawsuit also challenges the bundling of AMC and appraiser fees, a practice the CFPB explicitly permitted in its 2013 TRID rulemaking. This is where the analysis of Rich Horn becomes important. Horn is a former attorney at the Consumer Financial Protection Bureau who worked on the development and implementation of the TRID rule and is now widely regarded in the mortgage compliance world as one of the leading experts on TRID’s history and interpretation. In his article discussing the Florida case, he reminded the industry that Congress made AMC fee breakout optional, not mandatory, and that the CFPB declined to require it out of concern for information overload. That history gives lenders and AMCs a federal compliance argument, but Horn also emphasized the uncomfortable truth. TRID compliance does not eliminate state law claims of deception or unfairness. California has already demonstrated that in practice. Florida may soon do the same.

This is where the industry’s long running narrative begins to unravel. For years, AMCs have insisted that transparency would confuse consumers. Now consumers and courts are asking why transparency is so frightening. If borrowers truly benefit from AMC involvement, why must the AMC’s fee be hidden behind the word appraisal? If AMCs truly add value, why do appraisers report being prohibited from disclosing their own compensation? If the AMC’s role is so essential, why does the business model collapse the moment borrowers learn what portion of their payment actually reaches the person doing the work?

The irony is almost poetic. The consequences may be historic.