Maria, considering bid down appraisal fees often start with a 2 in San Diego County, consider yourself to be extremely blessed to have fees at $375.

By the way, with 800+ appraisers in San Diego County alone, we represent 1 out of every 80.

Seek the truth.

Did you catch IW today? More Darrien Gap ngo news, beyond shocking. The army marches on. Tens of thousands every day now, headed to a community near you, literally.

‘the amc’… I have identified your primary problem. Just apply with Guaranteed Rate already, geesh.

Pat, I just got an offer for 1004 for $375. All they can offer without going back to the lender. I reminded the AMC there is a Dodd Frank Act: appraisers needs to be paid customary and REASONABLE fee….This company shows the appraiser fee, and I know they take ~20%. So mortgage companies are as much in fault as AMCs.

The entire international banking system has already collapsed and we are going through the convulsions of that collapse. The bankers have lobbied their puppets in government to convert to CBDCs as the “solution” to their folly hoping that it will hide their malfeasance along with a series of “emergencies” such as another pandemic, WW III, ET aliens, border crisis, and God knows what else. A Convention of States to dissolve the Federal Government is about the only peaceful legal alternative, but that will only work if a lot more people soon see how the albatross of Empire has corrupted our elite in Rome on the Potomac.

https://dsnews.com/news/10-31-2023/zombie-foreclosures-are

Related. Foreclosure stats. If prices come down, and inflation comes under control, we could see a wave of foreclosures hard to imagine. How about nearly a million under current economic conditions just for starters. Remember when I was talking about researching treasurer public default notices? Yeah, and then some. The trend continues.

Thanks Mark. For appraisers whom built our entire careers on consumer protection, we’re cooked.

https://dsnews.com/news/11-01-2023/examining-the-impact

That was an interesting article on low volume and low rates, the ‘lock in effect’. The real chilling factor is there is still adequate volume so every single remaining appraiser could be busy and working today. Except the industry managers have already funneled well over half of our workload out to automation, waivers, or remote third party companies. Remember how they’d always preface the changes with; ‘this will have minimal effect on work volume.’

Does anyone have figures on how many appraisal requests never materialized in the past year, via the total mortgage volume? That’s how destructive the new policies are, sending nearly forty thousand appraisers right out of work. A few managers told me they deal with a half dozen desperate appraisers calling in daily. I’m not going to beg for work from a dwindling pool when there should be enough work volume out there to sustain this entire industry. People in support of automation, pdc’s, parea, and waivers at FHFA, Fannie, Freddie, and HUD deserve to be straight up fired for incompetency. The amc industry will persist and that’s how you’ll know, looking back years from now, this was a hostile industry take over by predatory interests. Consumers will be the ones most harmed by lack of full service experienced appraisal inclusion, especially into the future.

Excellent analysis.

Baggins,

What is the ACTUAL and LEGAL FEE?????
I would submit that it is the fee stated in the HUD 1!!!!

Maria,

Please forward me every letter that sets a fixed fee!!!
You are right, it is illegal.
We want the direct evidence!!!
Pturner@peturner.com

Maria, It’s all B S!

Maria, this FLS? Image attached.

Please save and provide screen clip images of this process of limiting appraisers fee entries.

Someone should provide that to the FCC in the vs Louisiana board case.

In reality though, what you are observing with an amc asking you for a fee survey is not a survey at all, but rather a litmus test. If you happen to enter a fee lower than any other appraiser, the amc will be inclined to give you a hell of a lot of work. Because you’ll be offering them a thing of value in return, as they’ll rake the difference between your fee, and the consumers fee, and will not return cost savings back to consumers as they should in a volume discount model. The appraiser provides volume discounts, the amc keeps the difference, consumer does not save a dime. Legal bribery. Pay to play schemes. Unearned fee raking. Junk fee billing. Basically, every day of the week activity for the amc industry. When dodd frank reg z first came around, there was clear guidance amc’s should have been fined $10k per instance, with $20k per instance if the violation recurred the next day.

That’s not a fee survey as you may perceive that as a lender asking. Since a lender would traditionally fee survey all their panel appraisers to see what the most commonly accepted regular appraisal fee would be, and that’s what they’d compensate to keep the appraisers working and retain as many of them as possible. With amc’s the process is different, because they’re vultures and thieves. The amc issues fee surveys to identify, then target in a predatory fashion, the appraiser willing to play ball. All the appraiser needs to do in order to steal all that work from other vendors, is play ball with the amc and do not disclose their fees to the consumers. Junk fee billing 101 but is effectively unregulated because with amc’s, only the one sacrificial appraiser holds a license, all the junk fee raking employees and owners are not required to be licensed and are never held accountable. Lender looks the other way, counting their increased income by offloading appraisal related management costs to the appraiser.

If you really have visual evidence of a fee cap that is sort of a big deal. Not like anyone will do a damned thing about it. All this other brazen criminal activity right there in the open for everyone to see and still, nobody does a damned thing.

You have been in contact with two different amc’s, within a weeks time? I have identified your primary appraisal problem.

Years back we were researching consolidation trends within the amc industry. Many start ups were bought up by some big box ones here in the US, as well as being bought up or somehow integrated into title companies, both US and Canadian were the trends. However the entire world is the limit when sensible standards are rescinded such as using licensed appraisers whom physically reside in the same state and can make it to said properties. Imagine raking half of a vendors fee from a world away and they would have no choice but to go through you in a pay to play scheme if they wanted to remain employed in their fields.

Additionally, the word has long since been out to mortgage department managers that if they utilize an amc, and especially if they form their own amc centric to that brokerage, they can rake back some appraisal fees as unearned fees not appropriately disclosed to consumers. Although likely not hand to pocket, the benefit is still there such as establishing additional margins for business write offs, freeing themselves of a few employee expenses, shifting that cost and liability to an ancillary company, aka the shell game. Voila! Additional profits on the books, although nothing really changed with volume. Offloading expenses to third party companies to increase profitability and stock prices, etc. But really the third party operational cost is borne on the backs of the appraisers and no longer borne by the lender in a traditional model. Which of course crushes the appraisers further. As my one appraiser pal used to tell amc’s, you’ve got a bright idea which has been done before. Unfortunately you can’t squeeze any juice from a lemon already squeezed dry.

For the comparative fee argument, that is a problem which is rooted in several issues, but primarily the federal reserves relentless devaluation of our currencies which builds to rampant inflation while promoting unscrupulous business practices. Keynesian economics if you will. One reason the US has been resilient to such a disconcerting end is the merit of scale and having dominance in financial systems, aka; the petrodollar. However, the effects of rampant inflation remain glaringly visible. They engaged in QE quantitative easing for so many rounds, and tried to bury it all in corporations and residential housing. Goldilochs is busting out and housing price appreciation going multiple times over within a mere decade or two proves this. First receivers skated off like bandits, but then again what’s new.

The imbalance for appraisal service costs specifically are best examined through a historical lense in comparison with realty agency and commissioned brokers percentage points for compensation of services. A long long time ago, $100k property, let’s just say off hand 5% agency and 2% mortgage broker commissions. There goes $7k off the top. Appraisal was $500 dollars. Otherwise a half point. Due to the affordable nature of housing and relative stability of the currency at least compared to today, real property and lending markets coasted along somewhat smoothly. People were less inclined to dip into homes like they were atm machines, and had more flex cash which was a major contributor to GDP gross domestic product and other factors pointing to a stronger economy. That was then.

Flash forward a decade or two to several dozen rounds of QE, many of which were not disclosed to the public and we only learned years later were distributed behind the scenes to first receivers of the money. Now there is a new dynamic. That same home in the same condition costs $400k. Mortgage commission and realty sales agent compensation figures slid back to account for the increased cost, while they maintained strong income gains. Being part of the sales service for that same home now compensated people in those industries 2x,3x, or in some cases if they were able to maintain that traditional high point model, a full 4x or more compensation comparative to what they used to earn. As home prices increased, they continued to get ahead. And every single time a home turned over, those agency fees were buried into long term amortization of the loans.

Irregardless if the loan package was sound or the people went under or were stable, all the people got paid a kings share. There was increased pressure to continue QE as well as provide capital and incentive to issue more loans more often. And just on a side note, the appraiser was still being compensated $500 per, but had some modest gains in efficiency where theoretically many appraisers could get twice the work done in half the time. So appraisers broke even for the most part but were able to keep up to a degree, while feeling that creeping chill of slipping behind, their end ever nearer as real world comparative income for appraisers slipped from on par to half, to a quarter of what commissioned agents make. Appraisal became a couch position or boutique business. And as many appraisers fulfilled those positions for consumer protection reasons, they were reluctant to push their fees quite as high.

And here is the zinger, what this essay is all about; The market resistance to increased appraisal fees is because the appraisal fee is one of the few hard costs which can not be financed into loan packages, while the majority of other commission based fees remained soft costs, able to be rolled into long term loan packages. Who cares about the thirty thousand compensation for agency when that’s just a few dollars a month on a thirty year amortization cycle? It was the cash out of pocket for the appraisal which really hurt.

Hence the lending and realty industries disingenuous cry for reducing appraisal costs. One; Because if appraisal fees would have kept up with other agency, we’d be getting $2k+ per appraisal right now (matching their comparative multiplier gains alongside inflationary trends). Two; Because by focusing on the out of pocket costs, this assists commission based agency in keeping the attention elsewhere, while they raked a years worth of income comparative to a regular job, for every few deals they put together in a months time, every ancillary service raking weeks worth of labor and income from every deal every time, aka; closing costs.

Banks do not set the appraisal fee per se. But with mortgage borrowers being against the wall on affordability in general, as whenever inflation happens effective income never keeps up with actual rising costs (the CPI is a tale of fiction and is nowhere near accurate due to behind the scenes first receiver handouts which are not accounted for). The bandits engage in a synchronous dance where in order to keep the gravy train going, they all point to the hard cost as ‘saving people money’. Hence the difficulty for appraisers raising fees. Enter the amc companies whom often drive up consumer costs, drive down appraiser vendor fees, and pocket the difference. Finally, someone was able to get that appraisal fee up! It’s about darn time. The progression of that activity of course is to perceive the whole appraisal fee as up for grabs. Enter PDC’s, hybrids, bifurs, desk only products, etc. Guess who’s going to still pay that full service appraisal fee, even though only a sliver actually goes to the appraiser. Winning! (lender and sales agents kicking alligator boots back on rainforest wood desks, cigars and fine whiskey in hand.)

The alternative would be for people to have skin in game with their sales efforts and be forced to pay out of pocket the entire load of soft costs, the entirety of agency commissions up front. Basically to eliminate soft costs. But then, how could they continue to bury QE in residential housing and associated mortgage efforts? One ponders why the appraisal can’t be included in soft costs, if they’re newbs. The appraiser is the only person compensated regardless if the deals go through. That increased appraisal fee which kept up with the times would really dig into peoples pockets if they were still paying a half point to the appraiser, and those loans never actually were originated. That activity might result in consumers actually paying attention where the money goes and perhaps dare to dream even slowing down on house flipping and paying loans off instead of constantly renewing them in the refried refi game. We certainly can not have that.

Tales of poisonous protectionism from the crypt. Most people can not fathom the elegance and effective nature of this system and decry lack of equity or blame individuals instead. Face the facts; brought to you by the federal reserve. Because if they were not inflating the money supply, that home would still cost $100k, and we’d all still be getting a fair share. People would be paying out of pocket hard costs for commissions, they’d get far better representation too. I’ll post this meme again, hopefully some will have a renewed understanding of what this actually entails.

I feel they turn appraisers against AMC, and they laugh. Small AMCs default, but the big ones eat from the same plate with the banks… We do not need AMCs, but do not forget, they were implemented to protect appraisers AGAINST BANK ACTIONS…. Mortgage companies again are the winners. Destroying the appraisal profession, and when the banks fail, blame appraisers, again… shiny future….

This week 2 AMC told me that they barely make money, and they explained it to me. Reasonable. There is a reason why so many AMCs were bought up by larger ones in the past years, escalating during/after Covid…keeping their name to fool everyone that there is still competition?

WARNING!

DO NOT FILL OUT FLS or other’s fee questionary!

I got from FLS a questionaries’ about the reasonable and customary appraiser fee. It will be illegal to use this data.
1. Third party has to do the research. They are not. (Neither AMC nor mortgage companies can conduct a research, per Dodd Frank)
2. They want implement a fee cap. They ask what would be customary fee in the area. The max you can chose is $600.

I just read the first question when I deleted it. More illegality might be present.

ILLEGAL, do not participate in it!

Fight with them after the “research” is done will be more difficult.

Mary that’s so rich. When the popular narrative is contradicted by the ACLU, of all the organizations out there, the ACLU… HUD people sitting around reading that; ‘We’ve got problems.’ Post that link over and over and over again. Will look forward to reading. The impossible find, wow.

I’m not even sure why I’m personally invested in this issue, nobody accuses me of such activity. It’s just, a never ending stream of anti appraisal industry destroying activity sanctioned by taf and the amc’s. They literally scheme every day of the week how to get rid of and diminish the independent appraiser.

DO NOT GIVE UP PLEASE!!!!!

Thank you!!