Read that article. Nobody even gives consumer choice a second thought. The separation from loan production rule which established the amc experiment has been an ultra mega epic failure that fueled corruption and crushed small businesses on a national scale. All the big players continue to play along. Independent sole proprietor appraisers whom care about consumer protection do not have an advocate. By proxy, consumers as well are often on their own to navigate predatory lending without help or any functional check and balance. Play ball of ride the bench. Appraisal modernization.

Truth. Accurate accounts from the time. Same thing again, different form. Last time around if an appraiser upset an individual mortgage broker for not making the deal work, the appraiser could call the person next to them whom was more honest and consumer protection orientated, chose to work with them instead. Even during periods of rampant fraud and appraisal value pressure, the ability for independent appraisers to voluntarily prefer one or the other individual mortgage brokers at the lending institution of the appraisers choosing based on careful research who was the more respectable client or not, this open market approach slowed down much damage.

When the individual licensed mortgage brokers openly applied valuation result pressure to appraisers, appraisers still had a choice to dismiss the ones violating ethical rules, prefer to work with other people instead. (Checks and balances which hindered the bypassing of rule spirit and intention of regulatory rules; consumer protection first.) That’s where the whistle blowers came from at the time. Licensed appraisers holding licensed mortgage brokers accountable via their direct engagements and direct communications. The problem at the time; appraisers were a much smaller group and were often subjct to enticement and manipulative practices which left the appraiser constantly scrambling for client replacement or appeasement.

Enter appraisal management companies. Where appraisers deal with people who’s own employment and compensation levels is tied to appraisal result based outcome which is beneficial to the lender. When appraisers upset an amc worker they don’t just lose the one connection for order assignment opportunity, the appraiser loses the entire company’s body of mortgage lenders, as well as every other originator whom may also contract with that amc.

Consider how many volume lenders work simultaneously with nearly every amc possible at one time. Fluid contracts. Constantly shared fee range. Approval and performance status. Success of closing outcomes data recorded and compiled long term. Data which the top amc’s in this country have boldly advertised as why their appraisal management company is better. Appraisers whom violate the advocacy rule are rewarded with the kings share. (Might have something to do with why despite the historical mortgage lending rush, the appraisal industry shed licensees instead of gaining them. Pro tip; it was not ‘valuation bias’ related.) Do not use and blacklisting data built in to the assignment platforms. ‘appraisal performance grading’. Enter what you’d like, label the activity however you would like, if the appraiser does not advocate for the lenders interests and rubber stamp these deals, that appraiser is no longer an ‘amc partner’ or ‘preferred tiered ranked appraiser.’

Appraisal independence. Separation from loan production rule. Appraisal management company top representatives sitting on appraisal oversight boards in every state in this country. Appraisal management companies being legally defined as ‘agents of the lender’. GSE capitulation. Sorry to bring the bad news to those still bothering to pay attention. Amc’s run the show now. Appraisal modernization.

I’m not even going to bother to title this meme. Come up with something if you’d like. Thanks.

Washington Mutual (WaMu) aggressively pressured appraisers to inflate home values to push more mortgages through. This systemic manipulation was a key driver of the 2008 subprime mortgage crisis, which ultimately led to the bank’s failure and acquisition by JPMorgan Chase.The WaMu Appraisal SchemeHand-Picked Appraisers: WaMu bypassed appraisal independence by allowing its own loan staff to hand-pick or “scrub” the pool of appraisers, favoring those willing to hit specific valuation targets. Blacklisting: Appraisers who refused to pump up valuations or who accurately reported “declining” market conditions were blacklisted, terminated, and stripped of future assignments. Targeting Third-Party Firms: The bank applied this pressure to major appraisal management companies like eAppraiseIT (a subsidiary of First American Corp).Legal Repercussions & Reform New York Attorney General Lawsuit: In 2007, then-NY AG Andrew Cuomo sued First American eAppraiseIT, revealing a damning paper trail of emails showing the company surrendered its independence to satisfy WaMu’s demands. Class-Action Lawsuits: Shareholders and affected appraisers also took legal action against the bank and associated appraisal companies. This included a $9.9 million class-action settlement over eAppraiseIT’s improper practices. Industry Reform: The fallout from WaMu’s practices directly contributed to the creation of the Dodd-Frank Act, which established a strict legal firewall to separate mortgage sales/brokering from the appraisal process.

Seek the truth.

Of course. If you don’t stop them, you only get more of the same.

Excellent, now the amc’s ceo himself will personally apply the pressure to their appraisers! HA!

This is how it goes down in the real world; Lender to amc manager; ‘Get the appraisers in line or we’ll replace you both.’

Appreciate the enthusiasm, I’m not so optimistic. They’ll rebrand, get a new controlling appraiser stand in, and no one whom approves the amc applications will be the wiser. The entire industry will know, but the state will still approve them. If you don’t approve the application the state does not get their money. They need to be approved and they will be.

If anyone gets uppity and starts talking about how the amc has a penalty in another state, that’s when the amc board member kicks in. Calls will be made, conversations will be had, the issue will simply go away. Because the penalty was not severe in the first place. And of course there is always the possibility that amc board member, it could be his amc company. All of them golf together on the weekends anyways. Welcome to real estate appraisal.

Maybe check the math. It needs to happen (number of appraisal management companies per state x the number of states x every single transaction the amc has ever handled.)

Can you believe how easy to run around the appraisers are? They’re still out there buying the amc lists from orep when in each and every single state, there is a publicly available list of every amc out there. Every single amc order comes with a lenders name and address they could solicit directly instead. Instead they work for half rate and assist the amc in defrauding consumers, look the other way on systemic billing fraud. Because they won the order, all they care about is themselves.

Half the people on state boards across this country have never worked directly with an amc, and if they did it was so long ago anyways. It’s obvious many of them do not have routine experience with MLS systems either. All these people talking about rewarding careers; most of them are not in service to the American public and have nothing to do with consumer protection.

The entire appraisal licensing program was supposed to be rooted around consumer protection so that when consumers engaged with mortgage lenders, they would not be absolutely fleeced and ran around. Now the same companies that fleece the consumers, that push independent appraisers out of the way, they keep one of their guys on the state appraisal boards. The other half of the board has no experience even doing the work, as they came from institutional settings as employees not independents. Can’t make it up. There is no comprehensive regulatory oversight. The appraiser becomes the fall guy for everyone elses malfeasance every last time. Prove me wrong.

The amc’s then take on working duties that are supposed to be lenders responsibility under SEC FHFA FTC DOJ oversight, and numerous other federal agencies, as well as being under the purview of mortgage lending licensing boards in each state. Thereby carving out a space where there is no regulatory oversight because state appraisal boards jurisdiction is limited to only ‘appraisals’ from ‘licensed appraisers’. Then the amc purposefully funnels as much work as possible to non appraisers to avoid the oversight. The amc’s industry lobbyists affected the structure of oversight to have placed a member of their own amc community (an agent of the lender) on the appraisal oversight boards of every single state, assuring they can quell any investigation into fraudulent activity before it gains momentum. With the additional benefit of redirecting and quelling all investigation which should be pointed at mortgage lending people and banking corporations.

To support all the fraudsters the amc industry now attracts like a magnet, promotes what is otherwise illegal activity such as non licensed property data collectors, automatic valuation utilities (that some of them maintain proprietary control of) instead of full service from an actual independent licensed appraiser. Promotes outsourcing. Carves out proprietary engagements with GSE’s themselves. Creates a non transparent system of grading and fee bidding which provides cover for blatant violations of AIR rules and FIRREA standards. Co opts the appraisal trade groups (many of whos top members are amc owners themselves) with enough power to oust a CEO whom did nothing more than tell appraisers they should get a fair fee from appraisal management companies (DF Reg Z C&R billing just like the VA still offers to this day). The amc’s are caught red handed doing all of this by the ARCC group and whistle blower testimony which is publicly available information. Engages in systematic embezzlement and junk fee raking of American consumers appraisal service fees in violation of RESPA rules. (image attached) Rules which should carry a year in jail and a $10,000 fine per individual instance, and they have done this for hundreds of thousands if not millions of federally regulated mortgage loan transactions. A thousand other offenses too numerous to list.

This is all that happens? Caught pressuring one single appraiser on one single deal. A year and a half suspension and a paltry fine?

Nobody does anything because state licensing boards to not have appropriate jurisdiction or authority to look into everything the appraisal management companies are doing. The regulatory oversight structure here is entirely deficient and dysfunctional. Amc’s permanently delist appraisers and suspend independent sole proprietor licensees every single day of the week for missing a checkbox or any other meaningless excuse they may dream up. Where are the investigations into all the other appraisers that worked for this amc company, the numerous transactions they’ve handled and quite possibly pressured appraisers, which has a cumulative effect on the entire economy and housing price structure? Or push a penalty to the mortgage lender whom is behind this? The amc is legally a representative of the lender, meaning the lender should also be held accountable. Not going to look into any of that or refer anything to the state DOJ? None of us can afford lawyers.

Dave Towne recently pushed an amazing article about an appraiser whom was caught red handed with felonious fraud and impersonation, something to that regard. That appraiser got two decades in federal prison. He’s late to the party because if he wanted to openly defraud everyone with backing and support from the associated industries, all he needed to do was operate an appraisal management company. He would not have even needed a perfect record himself, and could have used a stand in ‘controlling entity’ to pass the amc’s licensing application standards which are incredibly lax. The ‘managers’ providing the oversight of individual licensees are not even required to have licensing and there is no accountability and no oversight. The fraud has been right out in the open this entire time. The fifty thousand other people whom left this industry proclaimed decades ago; you’ll never get anywhere or correct anything, the appraisal industry and the people managing it are simply to corrupt. I suppose it’s good that someone did something. In the bigger picture though… Wake me when it’s over. I want to be buried in the discount cemetery.

Lori De hopefully the other states will also take action. I do know that some appraisers might not live full time in others states, or be boundary states but 2nd homes homes, etc. and be fully competent in those areas. (Doubt that is the case here)

Donna Halfpenny you know he’s licensed in 4 states and not one is within driving distance to the other. I can understand if he was licensed in VA, MD, DC and Delaware.