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.
- The Trainee Inside the Fast and Cheap Model - February 6, 2026
- The AMCs: Coming Soon to a Lawsuit Near You - January 20, 2026
- The 24-Hour Appraisal Funded by Appraisers - October 23, 2025
Took 4 years.
https://appraisersblogs.com/uncovering-flaws-in-fha-appraisal-n-loan-review-process/#google_vignette
Thank you Thank you Thank you, let’s keep this ball rolling
Well written post and blog
Excellent article! Glad to see this finally coming to light! The abuse has almost destroyed our industry and our ability to earn a living
The appraisal industry is no longer debating theory. It is confronting math.
The appraisal management company model was built on quiet assumptions. In 2025, those assumptions are being tested in court.
For years, AMCs claimed they existed to protect independence and streamline compliance. But recent class actions in California and Florida are forcing a different question: if AMCs add value proportional to their cost, why must that cost remain hidden?
In California, borrowers alleged they paid appraisal fees that bore little resemblance to what appraisers were actually paid. Research submitted to federal regulators showed AMCs retaining the majority of those fees. The court declined to dismiss the case based on TRID compliance alone, allowing claims of unfair and deceptive practices to proceed into discovery. That decision matters. It signals that disclosure rules are not shields against scrutiny.
Florida’s lawsuit raises the same issue. Borrowers allegedly paid hundreds more than appraisers received, with the difference quietly absorbed by AMCs selected by lenders—not consumers. Industry experts have correctly noted that while TRID allows bundled disclosures, it does not immunize deceptive conduct.
The industry’s long-standing defense has been that transparency would confuse borrowers. Courts are now asking the opposite question: what, exactly, is so dangerous about clarity?
If AMC fees are justified, they can be disclosed. If they are reasonable, they can be defended. If independence depends on concealment, then independence has been replaced with something else entirely.
The silence held for years. It is not holding anymore.
________________________________________
Five Changes the Industry Needs—Now
1. Mandatory Fee Disaggregation
Appraisal invoices must clearly separate the appraiser’s compensation from the AMC’s retained fee. Not optional. Not “upon request.” Mandatory at the point of sale.
2. Reasonableness Standards for AMC Fees
The customary-and-reasonable standard cannot apply only to appraisers. AMC retention must be subject to the same scrutiny, whether through caps or enforceable reasonableness tests.
3. Borrower Choice or Opt-Out Rights
Borrowers should be allowed to select from approved AMCs or opt for direct engagement where permitted. Forced payment to a non-negotiable intermediary is a structural market failure.
4. Prohibition on Compensation Gag Clauses
Any policy that prevents appraisers from disclosing their own fee to the borrower should be unlawful. A business model that requires secrecy is not a compliance model.
5. Re-Defining Independence
Independence must be anchored to professional judgment, not middleman insulation. Excessive fee extraction undermines quality, increases risk, and incentivizes speed over accuracy.
Kenneth J. Mullinix, Real Estate Broker
Certified Residential Real Estate Appraiser – California OREA #AR027585
Owner / President – KMA Real Estate Services
Appraisal • Inspection • Brokerage • Construction Consulting
FHA & VA Approved | 25+ Years of Experience | High-End & Waterfront Specialist
General Building Contractor(Inactive) CSLB #752435 | CA Real Estate Broker #01278660
Author & Industry Advocate – Working RE Magazine Contributor
949-697-1717 | kjmull@aol.com
So, basically follow the original intention of DF Reg Z on AIR. Or mirror the VA model with the IVPI proposal. That or ditch the separation from loan production rule and let borrowers have a say in sourcing their own appraiser.
https://www.workingre.com/wp-content/uploads/2013/08/IVPI-Proposalfinal.pdf
” 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.” This was the day Richard Cordray held the Democrat line and inflicted the first significant bleeder wound to the appraisal profession.
One additional line on the HUD-1 of the time was decided to be the limit of where the borrowing public could no longer comprehend the math which amounts to nothing more than that of a check register; simple debits and credits. Today’s version of the HUD-1 provides LESS information than before, which in my opinion creates LESS TRANSPARENCY than ever before. Almost everything that has occurred since the introduction of HVCC and Dodd Frank has created more opportunities for sketchy behaviors with “optional” compliance or only compliance at certain levels.
Every body tasked with the decision to enforce customary and reasonable fees passed it like a hot potato including the FRB and Ben Bernanke who stated “he didn’t want to interfere in a free market”. When he made that statement, the market and appraisal profession had already become a captive one. Another chance to enforce customary and reasonable fees forsaken and appraisers sold out. Sorry to make this political, but that’s what it is. Democrats have basically weaponized housing. Do your own research and see who had more political control when this all began back in the 1990’s. Billy and his everybody ought to own a home nonsense, leading to a crisis WE told them was going to happen (ignored because they were making too much money to stop it), which finally came to fruition because our government was certainly preoccupied with 9/11, and who came to the rescue? None other than Andrew Cuomo, (a Clinton appointee to Asst. Sec. of Hud in his first term and then Sec. of Hud in his second term) who is waiving his arms yelling ” I can fix it, I can fix it”. Of course you can, you were an architect of what broke housing and can now provide cover for the exposed democrat asses left exposed. Funny how the solutions to the problems came from those that did the most damage. Why hasn’t it gotten better? Democrats have continued to hold influential power over housing. Biden’s assault on appraisers started with “unconscious bias”, which as we got closer to the election turned to “bias”, and in the push to election, became outright “racists”. All totally fabricated and debunked the damage has been done. Marsha Fudge of course was helpful to our profession, right. Do you see the pattern yet? I’m not saying republicans are free of blame, but do your homework and you’ll see who’s put us in the crosshairs and has their finger on the trigger. I’ve posted this link before and it never gets old seeing how it becomes more true the longer this crap goes on.
https://www.federalreserve.gov/SECRS/2011/January/20110106/R-1394/R-1394_122510_58941_578175619525_1.pdf
I haven’t given much thought to how UAD 3.6 is intended to screw us more, other than expenditures for tech and training to have AMC’s offer even lesser fees wrapped in additional liability. Sometimes I’m having a good day and don’t want to ruin it by thinking about this crap. Mostly, I don’t see how without a cash hoard that would make Pablo Escobar jealous, we regain any control of our profession.
Great letter Brad. The fed has changed the link structures for finding these comments. Do you have the link where people could read the many different appraisers letters from that time? If so please post. You might as well have written that letter yesterday, everything in there is true, many even more so today.
“We will take you off our approved panel or blacklist you if you can’t reach x-value for our client”. ” / That blatant act of applied appraiser pressure has now evolved into something else. ‘Appraiser performance grading.’ The veiled excuse why appraisers can be silently removed from active rotation, deprioritized in assignment preference, receive far more or less order volume in disproportionate manners. Based on the amc and lenders own idea if the appraiser plays ball for their interests or not. The conversation between the lender and the amc goes something like this; (lender to the amc); “Get the appraiser in line or we’ll replace you both.”
This is the most conspicuously absent item from HVCC regulatory language; ‘Being required to notify an appraiser if they are removed from active assignment rotation.’ At the time and decades prior the industry standard was that if you’re good enough to be placed on a lenders approved appraisers panel, you would expect a fair share of work. Faster you turn the report in, faster you’re back in line for another. Rotational assignment principals. Lenders would provide fee surveys to find the most commonly accepted fee ALL their panel appraisers would accept, that was the basis for C&R or customary and reasonable fees. Similar to the model the VA still holds to today. Clearly the amc industry is not in compliance with fair compensation principals as described in DF Reg Z on C&R, as over three out of four appraisers refuse to work with amc’s. The fact the VA does perform comprehensive fee surveys, indicating a market rate standard for appraisal fee compensation which far exceeds the normal amc compensation. Consumers may pay more under the amc model, appraisers always receive less.
Amc’s cleverly found a way around both points by eliminating rotational assignment in favor of performance grading, which established a justification to select the minority body of appraisers whom provided the most thing of value; aka the lowest fee, and most appraisals which make deals work. in order to be the preferred appraiser receiving more order volume. In turn performance grading turned into a an open door for lies, deception, and systematically applied blacklisting whenever appraisers did not play ball with discount fees or value conclusions.
Tech companies hard coded this modeling into their platforms and now blacklisting appraisers behind closed doors is the new industry standard. Amc’s exponentiated the ability of lenders to apply value pressure for multiple reasons in multiple ways. Which is why we say; ‘amc’s, the long arm of predatory lending’. It’s much easier to apply this pressure with separation from mortgage loan production, as individually licensed appraisers could no longer file complaints or rebut directly against individually licensed mortgage brokers. Add on the amc representative, a legal agent of the lender, sitting on state appraisal oversight boards, a clear conflict of interest. The check and balance system is broken. There is no effective amc oversight mechanism.
Also I may add is a key reason why the amc and lending industry purposefully hires non appraisers for many roles such as panel management, activity relating to applied application of unethical activity and valuation pressure. If many whom fulfilled this role were individually licensed, license revocations.. The ‘controlling appraiser’ idea (one licensed appraiser required at every amc to force them to uphold ethical principal) is a failure. The appraiser managers are told the same thing down the line; get your panel appraisers in line or we’ll replace you both. The departure from rotational assignment opened the doors for never ending applied valuation and fee pressure.
Over 12 billion amc fee dollars raked, likely far more, as there has never been a comprehensive amc industry audit. Those monies created excessive compensation for appraisers willing to embrace the amc model at the executive level, growing amc influence and expansion. To further insulate from regulatory scrutiny and monetize the middle management process, many amc’s now specialize in sending more work to non appraisers, using many unfairly earned funds to branch into other lending spaces and commandeer other non appraisal activities still related to lending. Amc’s now function as a regulatory pass through; an ever increasing presence and influence in lending in general, being only overseen by individual state appraiser boards who’s only power is over individual licensees, not corporations of this nature.
The end result; Unreasonable influences which have eroded the trust, consumer data privacy, and long term viability of multiple essential checks and balances systems. Excessive waste, fraud, abuse. Fostering a climate where amc’s direct and control the appraisal industry rather than being a service to, increasing influence upon GSE’s which whom they have formed new special partnerships (pdc’s, hybrids, value acceptance, 3.6 uad forms, all a product of the amc industries influences.) A climate where over 75% of remaining appraisers refuse to be in service to the American public via GSE service, preferring rather to boycott amc’s entirely for ethical reasons.
Otherwise described by GSE’s as; ‘appraisal modernization’ and ‘value acceptance’.
I “think” the below link is what was available to comment on. R-1394 in the search brings up about 6 results but the date varied (10/18/2010 in my response vs. 10/28/2010 in the search results) and I’m trying to verify that now. While it’s been nearly two decades, i have a recollection a lot of the comments i read prior to my submission didn’t have their eye on the ball; playing along versus pushing back.
I searched several different ways for all of the public comments, however there may be a time limit on what presents in a serach as I was only able to get back to R-14xx in early 2011. An official FOIA request might be needed to get anything beyond that date? Have fun Bags.
Original proposal for comment
https://www.federalregister.gov/documents/2010/10/28/2010-26671/truth-in-lending
Interesting
https://www.federalreserve.gov/newsevents/rr-commpublic/docket_r-1394_meeting_11162010.pdf
Summary of input
https://www.federalreserve.gov/newsevents/rr-commpublic/docket_no_1394__summary_of_input_10282010.pdf
More Interesting…
https://www.fedsearch.org/board_public/search?source=board_pub&text=%22R-1394%22&submit=Search
Yes I’ve seen those before. Thanks for looking though. Sometime in the past year the master link which contained hyper links to all the individual comments was removed or moved. The public comments link does not work either. Mysteriously if you still have the link or a search engine indexed the link to an exact letter, they still host it. But they removed the master index pages and site references which gives access to all the letters. (Image), one should be able to access by manual link adjustment after the directory break (/), which does not work. Tried it many different ways, will not redirect.
I had previously posted a link to all the major letter writing campaigns master comments list. It was an html alternative format. A long list of every call to comment for every policy change or proposal for two decades or more, with every individually written letter behind them. One could pick the appraisal related issues like demins, tila, etc, out of that list.
Someone must have picked up on that, gone now. Appraiser input was considered a necessary hurdle to be summarily ignored. Who’s actually out there enforcing violations of administrative procedural rule non compliance? Nobody.
site:federalreserve.gov/SECRS/2011/January/
20110106/R-1394/
Something like that should work. It no longer works even without the ‘site’, I tried dozen different search engines. Interestingly you can find more and different letters on different search engines but generally none of them give more than two pages of return. I tried freespoke, quant, brave, duckduck, startpage, google, luxxle. It’s gone.
GOOD. Would love to see most AMC’s go down. They contributed largely to the demise of appraising. So many appraisers, year after year saying just add the fee’s they charge to the bid we would provide. Those appraisers never saw the bigger picture. AMC’s were taking in increased fee’s while managing to pay those doing the actual work (appraisers) less and less. Then AMC’s started to create their own rules outside of USPAP. If the appraiser did not want to comply and pay their fee’s, they received no work. AMC’s started out as one thing which was not bad. They morphed into a monster that still exists to this day. It’s time the appraisers took them down.
1. The quoted statement is factually accurate—and not political
“Congress made AMC fee breakout optional, not mandatory, and the CFPB declined to require it out of concern for information overload.”
That statement is correct as a matter of law.
• Dodd-Frank §129E did not require AMC fee separation on the closing disclosure.
• Congress explicitly chose optional disclosure, not mandatory transparency.
• The CFPB later declined to mandate breakout on the TRID / Closing Disclosure, citing consumer-comprehension concerns.
You can dislike that outcome—but calling it “political” does not make it false. It is a plain reading of statute and regulation.
________________________________________
2. “Information overload” was not a Democratic invention
The “information overload” rationale did not originate with Democrats as a partisan weapon against appraisers.
It came from:
• Long-standing consumer-finance behavioral studies
• Bipartisan consensus at the time that disclosures had become unreadable
• The same logic used to simplify credit card, mortgage, and RESPA forms going back decades
Whether that rationale was misapplied is a fair debate. Claiming it was a targeted attack on appraisers is not supported by evidence.
________________________________________
3. The HUD-1 vs. Closing Disclosure comparison cuts both ways
The post claims:
“Today’s version of the HUD-1 provides LESS information than before, creating LESS transparency.”
That is partially true, but the conclusion is misdirected.
What actually happened:
• The HUD-1 showed more line items, but less enforceable meaning
• The Closing Disclosure shows fewer lines but stronger consumer liability clarity
The real transparency failure is not the form.
It is the absence of mandatory fee disaggregation, which Congress intentionally declined to require.
That decision was:
• Legislative
• Bipartisan
• Influenced heavily by lender and settlement-industry lobbying, not party ideology
________________________________________
4. Customary & Reasonable fees were abandoned by everyone—not one party
The post singles out Ben Bernanke and Democrats.
That is incomplete.
The reality:
• Federal Reserve (pre-CFPB): avoided enforcement
• CFPB (post-Dodd-Frank): declined rulemaking
• HUD: never had enforcement teeth
• States: inconsistent and under-resourced
• Courts: deferred to regulators
This was a systemic abdication, not a partisan one.
The market became captive because no regulator wanted ownership of enforcement risk—not because of ideology.
________________________________________
5. HVCC and Dodd-Frank were responses to documented fraud—real fraud
HVCC did not appear out of thin air.
It followed:
• Widespread appraisal coercion
• DOJ settlements with major lenders
• Evidence appraisers were being pressured to hit numbers
You can argue HVCC was poorly designed (many do, correctly).
You cannot credibly argue it was invented as a political attack on appraisers.
It was a blunt regulatory response to documented abuse.
________________________________________
6. The Cuomo / Clinton narrative is historical cherry-picking
Yes, Andrew Cuomo played a role at HUD.
Yes, Clinton-era housing policy emphasized homeownership.
But the claim that Democrats “broke housing” ignores:
• Republican-led financial deregulation
• Bipartisan failure to regulate derivatives
• Universal political support for credit expansion
• Wall Street’s dominant role in shaping outcomes
This was a shared failure across administrations, not a one-party conspiracy.
________________________________________
7. “Weaponized housing” vs. what actually changed under Biden
The post claims appraisers were branded racist for political gain.
Here are the facts:
• Unconscious bias language originated in academia and HR, not campaigns
• The Biden administration did not change appraisal law
• No statute created appraisal racial liability
• No enforcement regime was legally expanded
What did happen was rhetorical overreach without statutory backing. That is a rule-of-law failure, not a political one.
________________________________________
8. Marcia Fudge did not regulate appraisers
Despite insinuations, Marcia Fudge:
• Did not control appraisal licensing
• Did not change USPAP
• Did not mandate fee controls
• Did not expand HUD jurisdiction
HUD rhetoric increased.
HUD authority did not.
Those two things are not the same—and conflating them is a mistake.
________________________________________
9. The real through-line is institutional cowardice, not party politics
Here is the uncomfortable truth:
• Congress avoided mandatory transparency
• Regulators avoided enforcement
• Agencies protected budgets and optics
• Everyone blamed “market forces”
Appraisers were not targeted because of politics.
They were expendable because they lacked institutional leverage.
That problem persists regardless of which party is in power.
________________________________________
Bottom line (tell-it-like-it-is)
• The quoted statement is factually correct
• The post’s political framing is selective and emotionally driven
• The damage to appraisers came from non-enforcement, not ideology
• Both parties benefited from avoiding accountability
• The real failure is structural—not partisan
If the profession wants solutions, it needs statutory clarity, jurisdictional limits, and enforceable rules—not partisan narratives.
Politics makes for good venting.
Law and structure are what actually fix things.
AI spam. No thanks.
In NY State we are required to include an Invoice separating fees; boy, the AMC’s still fight this saying to just “attach” it as a separate document. Truth be told a lender doesn’t even have to use an AMC to order an appraisal, it’s just that they are used to it by now. If FannieMae and FreddieMac are so concerned about saving the borrower or homeowner money do away with the AMC all together, we could still make a fair fee and save the borrower a lot of money. I did an appraisal not long ago, my fee was $1500 (3 hours each way), the borrower was pretty vocal about having to pay $3,000 for an appraisal and I couldn’t even give him a copy. All I said was that his loan officer would forward him a copy. But this kind of thing is happening every minute of the day, AMC’s have to go!!!
Appraisers whom continue to accept assignments from acm’s support and uphold the amc industry. The issues are not that complex, they revolve around basic ethics. If you know the company you work with is defrauding consumers; Is that an unacceptable assignment condition? Yes or No.
Good
It took me way too long to realize that this was not directly referencing AMC theaters lol
Where’s Baggins input? After 22 years of dealing with these dirtbags, it has become disgraceful and beyond criminal that these AMCs continue to do as they please and choose whomever they want to perform services. They will tell you in a busy area that they have no assignments and will keep you in mind, etc., etc. They want the cheapest tool and labor while reaping all the profits. I’ve complained about it for years to the upper brass of all these AMCs, and it’s gotten nowhere for no one! QL/Rocket has been involved in so many cases with these issues, and yet it will outsource most of its work to Solidifi. Solidifi will bully you and punish you with outlandish revision requests to get you to stop taking their work, so they can continue using their shoo-ins and favorites who do exactly what they’re told by the lender, especially for a fraction of what is deemed reasonable and customary. Class Valuation, CoreLogic, Clear Capital, Nationwide, PCV, AMC Links, etc., are all about making money and using only the ones that do as they are told. They love the hometown sweatshops that use trainees and non-licensed companies to knock these reports out in record time when the assignments are sent to that one company that has only 1 certified appraiser on file, but is receiving 80-120 assignments per month! They do not care and feel they have the financial strength and legal justification to continue acting as they please without repercussions. I truly hope it goes to a VA-style portal for all lenders nationwide to use, without any ties to favorites or criminality. This has been talked about for decades now 🙁
Thanks Adam. Wrote another essay summary in the above commentary. Outright cheating on order volume. Nobody does anything about it. We all know it’s happening and is the mainstay of the entire amc industry.
When will anyone tackle the primary issue of the unchecked nature of applied appraiser pressure, the departure from required appraisal service, absence of rotational assignment principals? Think of amc billing fraud as a convenient additional bonus that happened downstream of the engagement models being altered to facilitate institutionally applied valuation pressure and every day appraiser blacklisting. That’s where all this started. Back to the basics.
The VA actually pays fees that are reasonable and customary from what I’ve observed. They’ve kept up with inflation to some degree, while the balance of the work seems to have this notion that appraisers are not affected by inflation. This is the precise reason that many of us are barely making what we made 20+ years ago. I have been asked if I have the tech resources for the new UAD3. NO, because I can barely afford my bills combiined with my business expenses now – no extra money for more tech fees.
I started telling borrowers long ago that I only got 25% to 50% of what they were charged for the appraisal. When they asked what the AMC did, I told them “nothing”. Now, at the peak of the refi boom, I got a couple of very good fees, but I had to drive about 400 miles on each of those and spend a week each of work doing those appraisals. Now they whine and cry when I want a third of that to do the same jobs. I just hand them a Kleenex.
BTW, I’m still getting bids, but I no longer even look at them.
Appraiser Fees Collapsed. Now They’re Rising — Here’s Why.
By Kenneth J. Mullinix, Certified Residential Appraiser
For over a decade, appraisers have been working harder, longer, and for less money. Everyone knows it, nobody in authority wants to admit it, and the people who broke the system (AMCs, lenders, and federal policymakers) pretend they had nothing to do with it.
The truth is simple:
Appraiser fees collapsed because the industry allowed middlemen to cannibalize the profession.
And now — finally — the pressure is reversing.
This isn’t a feel-good story. It’s a wake-up call. Fees are rising because the workforce is shrinking, the economics no longer make sense for most veterans, and the next generation isn’t signing up for this job.
________________________________________
A 15-Year Lookback: How We Lost 40–60% of Our Purchasing Power
Between 2010 and 2012, a typical 1004 fee (non-complex) looked like this nationwide:
• $400–$500 conventional
• $450–$550 FHA
• $500–$700 VA (panel-specific)
By 2020–2023, the effective take-home for many appraisers cratered due to AMC fee skimming:
• $275–$425 conventional
• $350–$450 FHA
• $350–$450 AMC-ordered loans
• $65–$85 per hour effective rate once stips, ROVs, and desk reviews were factored in
The profession didn’t just stagnate — it went backwards, at the same time inflation accelerated.
Appraisers were doing more work, more pages, more photos, more commentary, more compliance — for less real income.
________________________________________
Who Caused the Collapse? Let’s Stop Pretending.
There’s no mystery here:
1. AMCs siphoned 30–60% of the fee off the top.
Nobody else in real estate gets paid before the professional doing the actual service. Appraisers are the exception.
2. Lenders shifted underwriting burdens to appraisers.
Every “clarification,” every “stip,” every “condition” is time you’re not paid for.
3. Regulatory chaos made appraisers the scapegoat.
Every time a federal agency fires off a new guidance letter, appraisers take the hit — more pages, more risk, same pay.
4. Appraisers left the industry. Lots of them.
The single strongest factor in the recent fee rebound isn’t policy — it’s attrition.
________________________________________
The Workforce Shrunk — and That’s Why Fees Are Rising
Appraiser numbers have dropped nationally from the 2013 peak by tens of thousands.
In some markets, the local panel has lost 30–50% of its active appraisers.
And here’s the part nobody wants to say out loud:
The people leaving aren’t the rookies — they’re the veterans. The high performers. The backbone of the profession.
When the most efficient appraisers leave, lenders face:
• fewer qualified panel members
• longer turn times
• higher bid requests
• rising fee demands
Economics took over where regulation failed.
________________________________________
2024–2025: The Rebound Begins
Here’s what the industry is actually seeing right now:
Conventional + AMC Work
• Bid-up pricing increasing 10–25% in many states
• Rural and high-demand markets seeing $500–$650 again
• Complex assignments regularly going $750–$1,200
FHA Work
• FHA turn times have stretched
• Fees rising to match VA in many markets
• Fewer FHA-certified appraisers are still active
VA Fees
VA has been the gold standard for consistency.
Current VA fees in many markets:
• Texas: $525–$650
• California: $650–$800
• Florida: $500–$650
• Northeast: $700–$850+
In multiple regions, VA fees exceed conventional AMC fees by 40–70% — an embarrassment for the rest of the industry.
VA Panel: Why It’s the Gold Standard — And How to Apply
If you’re serious about stabilizing your business and escaping the chaos of AMC bidding, the VA panel is the gold standard. VA fees are publicly posted, consistent, and typically 30–70% higher than conventional AMC work. Turn times are reasonable, communication is professional, and you’re treated like a licensed expert — not a commodity. Every appraiser who qualifies should apply. The VA makes the process straightforward: you submit your credentials, sample reports, a résumé, and pass the background requirements. Start here:
https://www.benefits.va.gov/homeloans/appraiser.asp
________________________________________
Why Fees Will Keep Rising Through 2026–2028
Whether people want to accept it or not, the trend is locked in:
1. The pipeline of new appraisers is still weak.
Trainees can’t get sponsors.
This won’t fix itself overnight.
2. Older appraisers are retiring or switching careers.
The ones who stayed through the PAVE panic and the price wars are done donating their time.
3. Mortgage volume will likely rise in 2025–2027.
Refis are on the horizon again.
With a smaller workforce, this means higher fees.
4. Lenders are being forced to abandon “lowest bidder wins.”
Turn times and quality are beating bargain-basement pricing.
5. Litigation and federal scrutiny are waking the industry up.
Everybody now knows this:
Cheap appraisals create expensive problems.
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What Appraisers Should Do Right Now
1. Stop taking bottom-feeder AMC orders.
You aren’t helping the industry — you’re subsidizing the race to the bottom.
2. Set your minimum fee and stick to it.
No serious profession negotiates down to poverty wages.
3. Focus on FHA and VA if possible.
Better fees. Better structure. Less nonsense.
4. Don’t apologize for charging what the work is worth.
You’re a licensed professional. Act like one.
5. Consider going lender-direct or private-client.
Appraisers who cut out the middleman are seeing the biggest financial gains.
FHA Panel and how to apply: Why It Matters — And How to Get Approved
If you’re not already approved for FHA assignments, you’re leaving money on the table. FHA work remains one of the most stable, high-demand segments in residential valuation, especially in slower markets when conventional volume dips. FHA turn times are consistent, the scope of work is clearly defined in HUD Handbook 4000.1, and in many regions FHA fees now rival or exceed conventional lender-direct fees. Getting approved is simple: you must be a state-licensed or certified appraiser in good standing, meet the HUD roster criteria, and submit your application through the FHA Connection portal. Start the process here: https://www.hud.gov/program_offices/housing/sfh/appraiser/appsb001
________________________________________
Where Fees Are Headed Next
My forecast — based on workforce declines, volume projections, and lender risk trends — is straightforward:
• Conventional: Stabilizing at $500–$650
• AMC conventional: $450–$600 (AMCs will shrink margins under pressure)
• FHA: $550–$700
• VA: $650–$900 (depending on region)
The days of $325 appraisals are dying.
Not fast enough — but the reversal is happening.
________________________________________
Final Word
For years, the only people talking about appraisal fees were the ones taking the money out of appraisers’ pockets. The profession was expected to work more, worry more, and earn less.
That era is ending.
The market is correcting.
The workforce is shrinking.
Appraisers are regaining leverage.
And it’s about time.
About the Data in This Article
Every figure, trend, and industry pattern referenced in this article is drawn from public, verifiable sources. This includes ASC registry statistics, VA regional fee schedules, state and national fee surveys, Working RE and OREP market reports, FHA/HUD Handbook 4000.1 guidelines, AMC margin studies, and federal appraisal workforce data published through AI, AQB, and FHFA. Nothing in this piece relies on confidential information—only publicly available datasets that,
One of the AMC companies I dealt with some years ago actually offered assistance – a special program designed for trainees to complete hours while under the guidance of a remote mentor. I had thought at the time that nothing replaces actual trainee/mentor interaction during those first months/year while on a physical inspection.
If I could actually make a reasonable income in this busiiness, I might be able to afford an accountant to assist me with a tax problem – the only reason I have not applied to be on the VA panel. I’ve been putting business expenses on credit cards because I no longer have the income to pay in full. I cannot afford medical/dental expenses, my vehicle needs tires (I do a lot of driving) and I cannot afford tires. I’ve been looking for another job, but at my age, with my other experience being many years ago, I am consistently told “we’ve chosen another candidate” (nearly 200 applications in the past 2 years). I’m taking classes, but they take time.
I do not want to complete UAD3 reports for even less income then I have now and dread continuing in this profession.
I think many of us are rowing the boat with you. One AMC went from just assigning at “almost” a respectable fee to email blasts for fee and turn time. After at least 100 of those producing ZERO orders, I made the decision that if I was going to be broke it would be on my terms and not by helping the enemy kill us the rest of the way by joining the race to the bottom. Good luck.
The fees stopped making sense by March of 2009 for Christ sake! Work load doubled overnight and fees were reduced by half. Entire rosters of hard earned clients evaporated for most appraisers.
There are honestly appraisers out there who are just beginning to figure this out?
When you say the fees are rising, I assume that you mean fees are finally getting back to where they were in 2009. We were charging $400 to $700 for typical residential work prior to March of 2009 and turning away three times more orders that we were accepting.
If you (or any other appraiser) are elated over $500 to $650 for a standard appraisal fee I worry about you guys. You do realize that your work load is about to double again with the new forms…right?
Show me a $1,000 fee for an 800 sf single family home appraisal and I’ll show you a guy who would consider reentering this lousy profession.
And those AMC’s are just a few! There are much larger ones out there Reasonable and customary fees somehow evolved into a bidding war to see who could get to the bottom first! This was never meant to be, no real regulation was ever drawn up. 
It should be two separate fees on the closing statement. It won’t make the closing statement any more confusing
Go back to direct lender-vendor engagement now that AMCs have demonstrated they do nothing to mitigate the lender and investor risk objectives. The lack of basic transparency and mostly inadequate management has only increased the associated collateral and valuation risk. From years with a large regional mortgage bank, direct appraiser engagement provided demonstrated feasibility and appraisal quality that while with additional cost brings additional integrity to the appraisal process, the lending institution, the investor, and the consumer.
A comprehensive summary of twenty years of amc mismanagement and misdirected regulatory changes into one solid paragraph. Great post.
You’re not supposed to talk about things like; independent engagement, volunteerism, right to work, the ability for mortgage lending borrowers to source their own valuation service contractors. That is not how central planning works. How will these companies maintain a monopoly if people have choice? You’re going to upset the stake holders. Nobody is supposed to question appraisal modernization. The concept of modernization only works if there is no alternative choice to return to decentralized models, voluntary based engagement in a free market. That’s why you have no choice, and are not allowed to talk this way. I’ve drawn up a special meme for the occasion.
The lawyers should start class action. I have so much dirt on clear capital and opteon. Both viper AMCs
Send it to ARCC. Link is in the article. It’ll take a miracle. All anyone needs to do in order to acquire real time evidence; is sign up to work for amc’s as an appraiser. Everything is right there out in the open. Nobody does anything about it. Most appraisers don’t even file complaints anymore, they know the amc rep on the state board is highly likely to get them or their associates blacklisted if they do so.
Lets hope thst this actually ends in meaningful results not another greased palm and status quo lobbying payback. This is how we got into this friggin mess in the first place. Just wait until 3.6 comes out in full force and watch the AMC’s bitch, cry and moan because they cant find appraisers. YA, get ready amc’s because you wont find any appraiser worth their signature to do your cheap 50-60% skimmed off bid jobs at $250-350 per appraisal when our workload has increased 30-50% just on the inspection end, not to mention the added reporting requirements. I send EVERY SINGLE insulting fee bid email from these croks to the ARCC and CFPB.
Why is the appraisal fee pad by the borrower? The lender is required to obtain an appraisal under specific circumstances. And, lenders can require an appraisal under other circumstances. Before 2009, at which point AMCs began to pop up like dandelions, the lender typically paid the appraiser. Once in a while the appraiser collected at the door, but that practice was not an everyday occurrence. Bottom line was, the appraiser was paid the entire fee collected for an appraisal.
Fast forward to 2010 and beyond. I remember 2010 being a very miserable year. With the exception of one, I lost all my bank clients that year. I began the AMC scramble. And the fact was, the AMCs had plenty of work for me, BUT, there was a catch! My $400 fee very quickly became a $200 fee IF I wanted appraisal assignments from an AMC. You know who got the other $200, the AMC.
So appraisers were immediately extorted. You want work, you pay us half the fee. You don’t pay half the fee, we will find the appraiser that will and you will not receive assignments from us!
Now we fast forward to 2025-2026. AMCs have continued their extortion tactics, even improved them. If you want to work for an AMC now, you BID on the assignment, which eventually will end up in the hands of the “LOWEST” bidder. All the while, in most cases, the borrower is charged an APPRAISAL fee by said AMC. In many cases the fee is somewhere in the neighborhood of $800 – $1,000. So, the appraiser that bid the lowest, needing to pay his mortgage and put food on the table, received the assignment with a bid of $300. Thus the AMC received between 62.5 and 70 percent of the fee paid by the borrower. However, this is not disclosed to the borrower AND, the borrower is not allowed to “shop” for a better appraisal fee.
ARCC (the Appraisal Regulation Compliance Council) has developed PROOF, that these extortion practices have cost borrowers across this country some $12 BILLION Dollars over a ten-year period. BILLION!
Hopefully these lawsuits change the scenario! The lender is the one that is required to acquire an appraisal. It should be the lender that pays the appraisal fee! If they choose to use an AMC (which is NOT a requirement by the way), the lender should pay the AMC they have hired, just as they would pay employees were they to have their own in-house appraisal department.
It’s high time the extortion from the AMCs stops.
To be fair, not ALL AMCs operate in this manner.
Why is the appraisal fee pad by the borrower? The lender is required to obtain an appraisal under specific circumstances. And, lenders can require an appraisal under other circumstances. Before 2009, at which point AMCs began to pop up like dandelions, the lender typically paid the appraiser. Once in a while the appraiser collected at the door, but that practice was not an everyday occurrence. Bottom line was, the appraiser was paid the entire fee collected for an appraisal.
Fast forward to 2010 and beyond. I remember 2010 being a very miserable year. With the exception of one, I lost all my bank clients that year. I began the AMC scramble. And the fact was, the AMCs had plenty of work for me, BUT, there was a catch! My $400 fee very quickly became a $200 fee IF I wanted appraisal assignments from an AMC. You know who got the other $200, the AMC.
So appraisers were immediately extorted. You want work, you pay us half the fee. You don’t pay half the fee, we will find the appraiser that will and you will not receive assignments from us!
Now we fast forward to 2025-2026. AMCs have continued their extortion tactics, even improved them. If you want to work for an AMC now, you BID on the assignment, which eventually will end up in the hands of the “LOWEST” bidder. All the while, in most cases, the borrower is charged an APPRAISAL fee by said AMC. In many cases the fee is somewhere in the neighborhood of $800 – $1,000. So, the appraiser that bid the lowest, needing to pay his mortgage and put food on the table, received the assignment with a bid of $300. Thus the AMC received between 62.5 and 70 percent of the fee paid by the borrower. However, this is not disclosed to the borrower AND, the borrower is not allowed to “shop” for a better appraisal fee.
ARCC (the Appraisal Regulation Compliance Council) has developed PROOF, that these extortion practices have cost borrowers across this country some $12 BILLION Dollars over a ten-year period. BILLION!
Hopefully these lawsuits change the scenario! The lender is the one that is required to acquire an appraisal. It should be the lender that pays the appraisal fee! If they choose to use an AMC (which is NOT a requirement by the way), the lender should pay the AMC they have hired, just as they would pay employees were they to have their own in-house appraisal department.
It’s high time the extortion from the AMCs stops.
Side Note: To be fair, not ALL AMCs operate in this manner!
Your comment; Published Fall 2025, WorkingRE. Great job.
AMC’s have bilked the American borrower out of 12 billion dollars. The ARCC compiled extensive data that reveals how unregulated appraisal management companies engage in unfair pricing practices, inflating consumer appraisal costs by nearly 15 billion between 2013 and 2023. This research clearly demonstrates the anti-competitive nature of the amc pricing model of hidden fees and it’s impact on borrower’s buying power.
If the lawyers have figured out how to generate substantial billing in a class action against AMCs we should have some great popcorn worthy theater to watch in the coming years. I’m 1000% here for it, especially with the jerks at Appraisal Nation. 🍿🍿🍿
An understandable sentiment. But only amc appraisers would get to be part of the settlement. It’s the amc appraisers whom deserve to lose their licenses the most. They facilitate the fraud by accepting unacceptable assignment conditions, knowing full well the amc’s defraud consumers. The amc appraisers understand they get prioritized access to work, that no other appraiser licensee can get, because they provide a thing of value to be the preferred appraiser, in violation of the USPAP management rule. All that’s necessary to be a successful amc appraiser is to play ball, discount enough so the amc can pocket a sufficient unearned fee billing rake, and look the other way on systemic consumer billing fraud. The consumer never saves a dime. The other three quarters of the appraisal valuation service licensees whom refuse to work with amc’s for ethical reasons have been excluded or blacklisted from working in this space, some for well over a decade. These are RICO violations, restraint of trade arguments. If amc’s are liable, so are the lenders. The amc legally defined as a representative agent of the lender. Lenders are acutely aware of how many fewer appraisers are available to them under the amc model. Those same lenders deal with an entirely different origination scenario when working with the VA. Can’t hide it.
It’s about time! I used to do contracted USDA work, before they gave it to an AMC company to handle the assignments. I never applied to get on their list. My point though is USDA insists you give them “your best pricing” for having the contract work. Which I always did – and it was much lower than customary. One of my RE brokers that utilized USDA for the majority of her borrowers was talking to me one day and asked why I wasn’t doing any of the work in her counties anymore, because the appraisers sure are getting paid GREAT now! I said “what???? Like how much?” She pulled up her HUD Settlement Statement and said “$750!”!!! Again I said “WHAT???? Are you kidding me??? Can you look through that appraisal for our state disclosure page where we have to state how much WE get paid?” She had no clue what I was talking about and just sent me the report. The appraiser was paid $350!! The AMC company was paid $400 FOUR HUNDRED DOLLARS! That’s more than the poor appraiser got paid for running around some rural county and putting that report together! It’s absurd. It’s also about time this comes to an end!!
It was really only a matter of time before we started to see litigation touching this space, and in fairness, it’s taken longer than some of us expected given the pace of industry consolidation and the proliferation of outsourcing models over the past decade.
For anyone in valuation, it’s no secret that the rise of AMC-centric workflows fundamentally altered the appraisal ecosystem: shifting assignment flow, standardizing pricing pressure, and creating layers of communication between the borrower, AMC, lender, and appraiser that can sometimes dilute accountability. Many appraisers have long expressed concerns about transparency, quality control, and the disconnect between market reality and AMC-driven expectations — not out of resistance to efficiency, but out of concern for defensibility, USPAP compliance, and sound professional practice.
At the same time, litigation — even when headline-grabbing — is rarely a silver bullet. It tends to highlight systemic weaknesses and sparks important conversations, but it doesn’t automatically fix underlying business or regulatory issues. What will move the industry are sustained efforts to improve data quality, clarify scope expectations, reduce process friction, and ensure appraisers are empowered to provide credible, unbiased opinions without undue external pressures.
My hope is that cases like this encourage meaningful dialogue between appraisers, AMCs, lenders, and regulators — not as adversaries, but as stakeholders in a shared market. We need solutions that protect the integrity of valuation, ensure fair compensation, and uphold the public trust that the appraisal profession is built on, rather than reactions grounded in fear or frustration.
In short: it’s long overdue, but what matters most now is how the profession learns from this moment and collaborates on practical, forward-leaning improvements.
That’s a good piece, professionally focused.
Except amc’s are not professional companies nor stake holders. They are legally defined as representative agents of lenders. Their primary function has morphed into specifically specializing in side stepping regulatory guidance and eliminating appraiser independence. They should no longer be called appraisal management companies as they appear to specialize in redirecting as much work away from appraisers, also having used their monopoly power and billions of unearned junk fee billing rake to capture many non appraisal related spaces which are integral parts of mortgage lending. Amc’s should be regulated at the federal level just like lenders. They should be required to have individual licensing for everyone involved. Even then, the amc functioning legally as an agent of the lender, should not have one of their members sitting in clear conflict of interest on state individual appraiser licensing boards.
Stake holders…. In a centrally planned system devoid of meaningful checks and balances. When do we the people and every day workers in this industry get a vote? When do consumers get their power back? The consumers right to choose whom their vendors they hire? There is no effective way for consumers to research anything in the realm of real property valuation as that pertains to mortgage lending. Lenders obscure their relationships with amc’s, use multiple amc’s simultaneously, steer customers to their profit centers, tell consumers they can not pick their own appraiser. The consumer has no choice, no vote in the matter. From a consumer protection and stable operation of gse systems standpoint, amc’s have been a total failure, enticing exponential increases in fraud, safeguarding nothing.
Value shopping never left. It only took on new innovative forms under the disguise of amc’s.
Missing the IVPI proposal yet?
https://www.workingre.com/wp-content/uploads/2013/08/IVPI-Proposalfinal.pdf
One main problem is that it seems the majority of Appraisers, ever since the introduction of AMC’s in 2010, chose to and still do accept the low AMC fees, thereby setting the fee watermark and ultimately ruining this once proud and respected and profitable business. Just one reason I have put my business on hiatus until things change which IMO will be around 2027 when REO’s (many of which will be connected to bad unsupported non-credible appraisals) will no doubt start hitting the market. Good luck to all Fee Bottom Dwellers, keep doing your chop shop low quality turn and burn reports for those low fees, your actions will be revealed in forensic review someday when you trip up. Oh, and remember, you can’t make edits to (or backfill) your work file AFTER you have delivered your report to Client and perhaps subsequently receive a Grievance or complaint….. thanks to time/date stamps on PDFs.
FNMA wholesale lending program serves as an effective cover to redirect defaulted properties directly into the hands of their partner institutional investors at volume levels never before seen. Thereby nullifying effective disclosure of insufficient and arguably regulatory non compliant appraisal engagement during forensic review. Foreclosure by design. Increased profits the result. Consumer protection removed from the GSE priority list years ago. Short sales have already returned, substantial increases.
Enter executive order curbing institutional investors from buying residential properties. Will it make a difference?
https://www.whitehouse.gov/fact-sheets/2026/01/fact-sheet-president-donald-j-trump-stops-wall-street-from-competing-with-main-street-homebuyers/
Source article.
https://appraisersblogs.com/fannie-mae-fraud-and-abuse-exposed/
Specifically this;
https://capitalmarkets.fanniemae.com/whole-loan-sales
Pepsi challenge; Tally up the total volume of principal default amounts over the entire term this program has been running. The figures are more than substantial. The reason why there is related news stories of institutional investors possibly currently holding 20% or more of all residential housing in the country.
Amc’s made all of this possible with their concerted efforts to steadily erode then eliminate appraisal independence. FNMA endorsed the behaviors with continuing appraisal modernization efforts.
With additional monetization of the data on the back end. The guy whom owns that company or somehow has a major stake, I do believe is an appraiser and also has sat on state appraisal boards, while simultaneously working hand in hand with top amc interests. He wrote articles in favor of uad 3.6 and modernization which proclaimed the appraisers will no longer be using clip boards and manual methods. I drew up a meme at the time to celebrate the occasion, titled it; Tony the clip board eliminator. / GLB is dead.
https://appraisersblogs.com/fannie-n-freddies-offshore-gambit-imperils-privacy-of-millions/
https://appraisersblogs.com/automatic-review-of-photos-in-appraisal-reports/
With AMC’s using Corelogic, there is a second middleman pilfering our fees. AND appraisers cannot still mention the 4 stages of a neighborhood without violating DEI and AMC rules as they get flagged by the AI that actually reviews our reports. The inclusion of AMC’s is worse than the damage NIL has done to college sports.
Make sure to thank the ARCC for bringing these true stories to life! These guys deserve credit where credit is due.
Can’t wait for the lawsuits involving you-know-who, the monopoly-hungry AMC that is building a roster of piss-poor quality staff appraisers while sending their fee panel appraisers to state boards for dubious reasons (except for the one obvious reason… to capture the market with their staff appraisers) and then kicking them off their panel.
Reparations for more than a decade of fees stolen from us?
Matt is correct, but also theft by the AMC’s from the borrower who pays the entire fee without knowing where it’s going. When NY State started requiring us to include an invoice the AMC’s went ballistic, threatening removal from their panel if we left in the invoice. I don’t work for “cheap” fees, either they pay my reasonable fee based on distance, time involved and complexity of the subject or not. So many time I get a request for an appraisal that is 2 hours away and complex; when i quote it I hear the AMC rep falling off their chair, but then invariably I get the assignment 2 weeks later as a “rush” assignment, after they have shopped it around. I’m not looking forward to the 3.6 forms, I don’t think anyone is, but I’m still in for another 5 years until I can retire…this profession has been good to me for the past 20 years and I still look forward to Mondays.