Everyone is in on the con.

Nobody will ever get in trouble.

The activity will continue unabated without restriction.

Soon, as fewer and fewer appraisers are involved with mortgage lending activity, the activity will continue in new forms with less oversight.

An amc agent of the lender sits on every state oversight for appraisers board in this country, guaranteeing that lenders will never be held accountable as well.

The illusion of ethical principals in the appraisal industry. Monetized. ‘Appraisal modernization.’

Missing the IVPI proposal yet?
https://www.workingre.com/wp-content/uploads/2013/08/IVPI-Proposalfinal.pdf

I don’t deal with AMC’s much anymore, but submitted a bid a couple days ago. I learned through the mortgage broker involved with the deal that the AMC increased my fee by $1,400 and added 2-weeks to my delivery time before submitting the bid to the lender. The lender was apparently surprised to learn what the AMC was doing.

Perhaps when they have enough complaints and concerns? I hope so!

That’s wonderful!

Hi C L.

Just posted in relation to the DOGE website news and DEI executive orders possible applicability to appraisal groups. Also pondered the question of compliance with existing federal rules on ‘research misconduct’, and the ensuing loss of work and career opportunities appraisers are currently facing.

https://appraisersblogs.com/appraisers-freed-from-dei-propaganda/comment-page-2/#comment-44510

Pretty messed up that “the system” has allowed this to happen isnt it.

Sacramento Real Estate Appraisal

Well done!!!!

Please provide ARCC with any information you believe would be helpful with their research

Bagging
Please call me again

If the CFPB is disbanded, would that also in turn mean the CFPB safe harbor interpretation on C&R customary and reasonable appraisal fee rules also be nullified and effectively rescinded? Meaning the entire lending community managing FRT federally regulated transactions, when then have to return to the original spirit of the DF Reg Z rule on C&R compensation of appraisers, and be REQUIRED to use fee surveys which DO NOT INCLUDE amc data as the basis for acceptable minimum appraisal fees or face mandatory $10k/$20k daily recurring fines?

Do you ever feel like you’re making the same valid legal arguments based on factual evidence over and over again and nobody listens or bothers to become educated on the rules governing their own industry? Image attached.
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Alamode (pre core logic buy out) 2x important fee reference articles;

Frequently asked questions regarding the appraisal fee reference

Fees, new rules new data

https://web.archive.org/web/20100418143229/http://www.appraisalpress.com/

And an image snip of the 2010 Biggers email

LSI & Landsafe!? Wow, 2003 is calling….

I just had flashback of an unintelligible call center stooge asking me to go literally across the state for $175 appraisal.

JR “I have several AMC clients that pay good fees and don’t shop fees. Sure some do. Most don’t” Sorry, but I have to call BS o this statement – at least in my experience I work a rural market and have worked with every AMC alive since before LSI and Landsafe – do you remember them JR ? I can name only 1 out of 150 that quote theiir fee on the LOE…. FLS – who else does that ???

Covered that already JR.
https://appraisersblogs.com/the-shadowy-appraisal-management-companies-fees-draining-billions-from-homebuyers/#comment-44128

How does a company with a financial incentive to drive vendors fees down and drive consumers fees up, then pocket the difference without any clear disclosure, how does that cost consumers more money? Is that seriously your question?

Amc’s are agents of the lender, are required to be subjected to adequate and meaningful oversight of the lenders they handle appraisal for, every single time for every single order, the full scale of compliance and accountability is supposed to apply. Care to explain the difference between a mortgage broker skimming junk fees which is clearly defined as illegal activity, and the amc doing the same thing, how or why that’s somehow acceptable when an amc does so, but not acceptable when a licensed mortgage broker does so?

This research is not all that difficult. If one cares to be educated on the matter. Image attached. Explain how if a basically equivalent service is delivered by the amc every time, what ‘additional service’ justifies such extreme variable and undisclosed fee rakes?
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https://www.fha.com/fha_article?id=232

There are also caps placed on fees to prevent “variation”. This prevents a lender from artificially inflating fees or charging for services not actually rendered.

“A lender’s mortgage charge rate (discount points, origination and other fees) may not provide for a variation of more than two percent on its FHA mortgages within a geographic area; and any such variation must be based on actual variations in fees or costs to the lender to make the loan.”
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Provide evidence that through the entire amc spectrum the amc variable fee raking is never more than 2% by specific location per FHA rules. Come to think of it, this is yet one more piece of evidence that can be rather easily documented by the ARCC. There are similar rules prescribed for mortgage lending fee disclosure and acceptable consumer charging outside of HUD rules as well.

Mike, I don’t work for an AMC. I have several AMC clients that pay good fees and don’t shop fees. Sure some do. Most don’t. There are bad companies just like bad people. I don’t work for them. Nobody here should. And if a fee is $500 to the consumer. Or $600. How does the fee split on the appraisal that is already ordered, a process which the consumer has no knowledge of, cost him MORE money? The fee is the fee. It was charged up front (typically). I agree on transparency being a problem but the amount of the fee is what is already charged so the idea that it is “costing consumer billions more” just because it isn’t disclosed is lost on me.

AMCs suck but they are part of the game. Changing forms and appraisal requirements and new appraisal types and products (waivers) are what our threat is. I’d rather go work during the day than constantly recite 15 year old Interim rules that never have and never will be enforced like something will mysteriously change.

The good news today is Sen Cruz is pushing to defund CFPB. That would help everyone. Or should. https://www.wsj.com/politics/policy/cfpb-consumer-financial-protection-bureau-ted-cruz-gop-defund-b831384c