ACS (America’s Criminal Syndicate) is a far better acronym than AMC.

Excellent, thank you.

Well, let’s ponder on that for a second. The law says an AMC must pay Customary and Reasonable fees to the independent fee appraiser (see Dodd-Frank). Extracts:

Reasonable: The fee reflects the scope, complexity, and requirements of the appraisal, adjusted for factors like:

Location of the property, Timeframe for completion, Appraiser’s qualifications, and Nature of the valuation (e.g., field review, full appraisal)

Customary: The fee is reasonably related to recent market rates for similar services in the same geographic area, based on surveys of actual fees paid by entities like the Department of Veterans Affairs (VA) or other market participants.

In practice, this means appraisers should not be paid less than what is typical for their work in that market, and AMCs or lenders cannot arbitrarily set fees below established market benchmarks.

The Federal Reserve Board (FRB) released an Interim Final Rule (IFR) regarding implementation of Dodd-Frank many years ago. A Senior Attorney on the board stated that AMCs and others would have to have some basis for not accepting an appraiser’s fee other than the fact that someone is willing to take something lower. There are two parts to the equation, she said: first is the customary and reasonable component as defined above, which takes into consideration the type of appraisal, location, appraiser’s experience, etc. The second part is the use of fee studies, fee studies that exclude AMC appraisals and studies!

There is also a thing called the consumer protection act. In Item 42(c) – Valuation for consumers principal dwelling, section 1 states: (1) Coercion. In connection with a covered transaction, no covered person shall or shall attempt to directly or indirectly cause the value assigned to the consumer’s principal dwelling to be based on any factor other than the independent judgment of a person that prepares valuations, through coercion, extortion, inducement, bribery, or intimidation of, COMPENSATION or instruction to, or collusion with a person that prepares valuations or performs valuation management functions.

Section 42(f) provides the Requirement to provide reasonable compensation to the appraiser. Section (i) states: The creditor or its agents compensate the fee appraiser in an amount that is reasonably related to recent rates paid for comparable appraisal services performed in the geographic market of the property being appraised. In determining this amount, a creditor or its agents shall review the factors below and make any adjustments to recent rates paid in the relevant geographic market necessary to ensure that the amount of compensation is reasonable.

Section (iii) discusses appraisal management companies and states: The term “appraisal management company” means any person authorized to perform one or more of the following actions on behalf of the creditor:

(A) Recruit, select, and retain fee appraisers;(B) Contract with fee appraisers to perform appraisal services;

(C) Manage the process of having an appraisal performed, including providing administrative services such as receiving appraisal orders and appraisal reports, submitting completed appraisal reports to creditors and underwriters, collecting fees from “CREDITORS” and underwriters for services provided, and compensating fee appraisers for services performed; or

(D) Review and verify the work of fee appraisers.

So… AMC’s have a duty to provide a customary and reasonable fee. The fee CANNOT be based on the appraisals they receive. But, most AMCs consistently state: “The fee we offer is based on what we are paying other appraisers in your area”, which actually violates the law. Additionally, many AMCs charge the borrower several hundred more than they pay the appraiser. Point in fact; Nations Valuation received 81% of the fee charged to the borrower. Clear Capital has received as much as 84% of the fee charged to the borrower and consistently receives 65% to 70%. Class Valuation consistently receives between 60% and 65% of the fee paid by the borrower. Solidifi consistently received 60% to 66%. And the list goes on. And… when the borrower goes to closing the ONLY thing they see in the closing document is an appraisal fee of $750, $800, $900, $1,000 and more. Yet the appraiser made $275, $300, $350, and typically not more than $450 (pre covid standard pricing for typical reports in many areas).

Something to ponder: If the closing statement, a legal financial document, states the appraisal was $800, would that not indicate a standard fee the appraisal. And should that be the consideration of what’s a customary and reasonable fee? And how is it AMCs are collecting fees from borrowers and skimming as much as 84% of the fee when Dodd-Frank explicitly states they collect fees from CREDITORS and underwriters? Thus, realistically, AMCs may very well be in violation with regard to fee splits.

Unfortunately for appraisers, AMCs have large pockets and fat wallets. They have infiltrated the appraiser regulatory system. So those that should be fixing the system are turning a blind eye. AMC Money talks and the appraisal profession suffers.

Just be thankful the phone company hasn’t caught on yet. If they were smart they would be demanding a cut of all fees placed over their phone / fax / internet lines rather than charging a fixed fee for services.

Oh, and FNMA filed a complaint against me 2 years ago for using the word “demographics” in my neighborhood description.. also thrown out by state board thank goodness due to no basis. Who wants to bet this “complaint” was initiated by REVAA attorneys?? If anyone is owed Reparations in the lending world it is the Independent Fee Appraiser. We are “Licensed to Steal from” apparently.

Racketeering. Restriction of trade. Theft of intellectual property. Discrimination against disabled and elderly. You know, everyday activity appraisers deal with that would be prosecutable offenses we could take to the doj, sba, and a great many other organizations in any other profession.

Thank goodness so many top people in appraisal trade groups, our own insurers, just about every single tech company we are required to pay into in this pay to play industry, all the way to the top of the executive fhfa and gse ladders, have an ownership stake in the appraisal management industry and keep a lid on all of this. ‘Stakeholder interests.’

Thank you. Not necessarily a fair sampling but is indicative of some issues.

Trust Pilot is often where people turn when their reviews are censored elsewhere. That’s how it works with review sites like yelp and others. The big companies buy into additional profile capability, make donations, make calls, fill out objection forms and entire segments and age ranges of reviews disappear.

Lets check in on yelp for good measure.
Could not find an amc specific for solidifi, odd. The name shows up in a hundred other different company yelp reviews as associated but not directly. That’s what I’m talking about with burying the record.

How about reddit.
https://www.reddit.com/r/appraisal/comments/1hczisz/solidifi_good_or_bad/

Oh, if you ask for a higher fee you get a lower profile score. Awesome. Penalize appraisers whom try and hold the amc to DF Reg Z C&R billing regulations. Appraiser independence at it’s finest. The pressure is built into the software platform itself.

Solidifi

37 reviews – 1.6 (Bad) Star Rating with over 95% ratings of one star. Kind of explains it all

I told you it was only a matter of time before more people dealing with these companies naked corruption would come forward with their stories.

Johnny Appraiser, write a real article on the matter, publish it here anonymously. Inquiring minds want to know. Thanks.

Back to the very beginning. The amc industry is doing a great job at protecting predatory lending, and making sure real independent appraisers are driven out or do not have a voice. Separation from loan production rule is a failure.

What would be so hard about doling out appraisal requests in a standard rotational manner so all panel appraisers got a fair share, and a customary and reasonable compensation rate? Why don’t they do that?

And if people argue against such simple principals of fairness and transparency, they’re part of the corruption. Makes you kind of wonder why FNMA gave CU direct proprietary access to the big amc’s….

Sure that can be important and may be a worthy effort. But the way the site admin allows bot crawlers and such, this website gets top hits with associated name searching. First page results is a pretty big deal too. What’s different is that we’re not participating within the big tech ecosphere with all their rules and controls. I tried to share so much of this on reddit, they nuked my entire account and deleted everything I’d ever posted over years worth of time. That’s big tech for you. This place is not an echo chamber per se. Sure there is a lot of lurkers and such. Comments here have substantially more searchability and indexed reference relation than if you post on linked in. Give and take, the complicated nature of the internet these days.

You know what happened on the Appraisers Forum right? These companies getting all the exposure from the good bad ugly forum threatened to sue that sites owner and the increased traffic drove his monthly connection costs up to the point of non sustainability, so he put all the GBU negative client exposure behind the login wall so that general internet researchers and quite a few bot content crawlers could no longer access the site. And just like that, when one searched specific amc or lenders, there was no longer first page hits of appraisers complaining and bringing the receipts on the AF. Linked in, facebook, they’re all similarly susceptible to the lender pressure, all it takes is a phone call. Meanwhile this site is by appraisers for appraisers and does not respond to pressure campaigns. The site is not monetized for someone elses benefit. If anyone wants to support the site, click on the appraisers directory up top and buy a little elevated listing deal. Thanks.

Never ending conflicts of interests. Under shared umbrella policies none the less. OREP and all the others should divest and choose only one party they will provide insurances for, the appraisers, or the amc’s. Providing coverage for both is clearly a conflict of interest issue.

But it’s nice to know a portion of our professional insurance fees goes to sustain the lawyers defending the amc companies whom actively drive independent appraisal businesses under. Imagine having EO insurance and filing a claim for a false complaint, for an amc company insured by the same insurer. You think there might be some imbalance there in the way they choose to represent a billion dollar CORPORATION vs a sole proprietor? With the same star lawyer…. These people actively destroy their own credibility.

What’s this AF reference all about?

The amc hassles are purposefully applied, sort of a sifting through the masses, qualification identification efforts. Most amc’s only want compliant appraisers who play ball and are not all that well informed on ethical principal or actual legal matters.

Let’s check out Trust Pilot for this company. That’s always fun. It’s where the people whom get really screwed over by companies go to complain.
https://www.trustpilot.com/review/solidifi.com

Never ending spam solicitations, no opt outs, adjusting charges higher on the fly, double charging. Borrowing consumers talking a lot of trash about their appraisers and process. Why does this company need five different BBB profiles?

Here is a good one, even an appraiser chimed in. / As a former appraiser, I can tell you that they are all about the dollar at Solidifi. THEIR dollar. The pressured me to overlook problems, asked me to fill out forms that weren’t appropriate, argued with me constantly, told me to be available holidays, weekends, etc. WORST AMC OUT THERE. AVOID AT ALL OPPORTUNITY

‘some quiet little network passing names around’

REVVA’s influence has spread to the appraisal trade groups. They’re in charge of almost everything now.

https://revaa.org/membership/#members

Let’s play the associations game and examine the degree of separation. This is so easy I did not even need to open up paint and accomplished this task with the standard image snipping tool. Image.
___________________________________

Solidifi was known for contacting disgruntled appraisers whom posted on online networks and social media as early as 2010. They’ve been keeping track of appraisers commentary this entire time. Anyone whom goes public whistleblower against these companies gets buried.

Check out the amazing philanthropic and charity work Solidifi engages in. Looks like really excellent benefits!
https://www.solidifi.com/solidifi-in-the-community/

They’re really big on pride! Appraisers should learn to qualify the companies they work with better and ask themselves if their values are even remotely aligned with the values of the companies they provide service to. When you work with thieves and moral degenerates don’t be surprised if you get burned.

Amc’s instead took on the role of being a part of mortgage loan production themselves. Amc’s have become loan production, they openly advocate for lenders interests and goals. They routinely blacklist and remove appraisers from active rotation for a variety of reasons, most certainly if appraisers upset anyone at all, the realty agent, the mortgage lender, a borrower, a seller, stalls out a deal in progress, identifies predatory pricing or asks people to renegotiate the price or pay cash differences. If the appraiser inconveniences people, especially those within the amc world who’s very job depends on satisfying and appeasing the desires of their lender clients demands, the ability to remove that appraiser from service is now a part of the automation, built into their assignment platforms. They set up meaningless performance grading metrics as a cover for blatant discrimination and routine blacklisting. Amc’s, the long arm of predatory lending.

Some quick stats; fifty thousand out of the previously one hundred and twenty thousand appraisers left this industry due to corrupt amc practices. Of the seventy thousand appraisers whom are left, the proportional share of certified generals has grown, meaning add another five to ten thousand or more to the number of appraisers the amc industry has driven out (as amc’s typically have no influence in commercial work which is why CG licensees continue to expand, while residential licenses continue to retract.) Of the remaining body of licensed appraisers whom focus on residential work, roughly three quarters of these appraisers have left mortgage lending and are no longer in service to consumer protection principals or participating in safeguarding GSE lending systems and the hundreds of millions of citizens whom rely on federally regulated mortgage access.

Because of the lack of service availability of appraisers, and the near impossible task of attracting new people to this god forsaken unforgivably corrupt industry where conflicts of interest are more common than not, the next big move to exploit consumers has arrived. Appraisal modernization. Automation of valuation results without using full service human appraisers. The data cancer is evident everywhere now. Bifurcated markets are the new normal. Events and market trends that were previously in isolation from each other, now happen simultaneously. We look at the MLS data, see excessive days on market, weak buyer acceptance, severely imbalanced supply vs demand, clearly declining and crashing price and value benchmarks. Yet there is always still a presence of highest and best sales that sailed through they system in a logical contradiction. Anyone with good credit no longer gets the benefit of full service appraisal and instead goes through the value acceptance, waiver, hybrid, and pdc programs, they get approved every time at peak price and peak value. Despite the fact there were lines of sellers desperately price slashing and negotiating at the time.

The automation imposed by amc’s and lenders whom support them, often coming from the very top of the GSE ladder has rendered the traditional Blacks law of fair market value to be nullified and meaningless. Any citizen going through the value acceptance, avm automation or watered down hybrid valuation programs is at extreme financial risk without adequate checks and balances or consumer safeguards. Not to mention the wholesale exploitation of overly granular data harvesting and monetized resale by the myriad of third fourth and fifth party companies all taking part and earning a kings share in the exploitative process of ‘modernized appraisals and automated appraisal’ activity.

Now these corrupted interests are actively promoting the franchise model. Where appraisers can magically maintain independence despite all evidence and pressure to the contrary, while operating in an employee model. Further rendering the concept of valuation independence as also nullified and inert. What made the appraisal industry robust and reliable in the past, was that all the appraisers were 1099 small business owners and nobody got to push us around or tell us we had to play ball or we’d get fired or blacklisted. But now that is the new expected business model for faux-independent appraisers. The people whom accept this are either stone cold stupid low IQ bozos, or they are part of the insider track making a fortune promoting the automation. The amc model is a total failure and even the very rare few decent amc’s are set at a severe market disadvantage by the predatory ones. What few lenders are left not utilizing amc’s have in turn adopted amc like methods themselves in order to stay competitive in the market. One can hardly tell the difference between any of the companies these days. In this industry you play ball and pay gratuity fees or you ride the bench.

Half the appraisal trade group leaders, most of the technical software companies, and most of the continuing education providers have substantial financial interests in amc’s and use their positions to promote the amc industry. Now we have companies like Regorra offering free appraisal software to data harvest intellectual property and exploit protected private consumer data in outright defiance of GLB privacy rules. We have RestB(dot)AI selling and transferring private home photos and invasive 3d scanning of peoples interior home spaces to overseas companies and their AI systems. We have companies like TrueTracts and their competitors operating exactly like amc’s and doing everything that amc’s are required to hold licenses for, without even bothering to hold an amc license themselves. GSE’s themselves promoted and developed the automation to facilitate the predatory lending activity. They give special privileges and CU systems access to the amc’s now. The amc’s have become mortgage loan production. There is no such thing as separation from mortgage loan production by way of an amc management company. There is no saving any of it. The irony of this supposedly being an industry who’s primary allegiance is to ethical principals.

Missing the IVPI Proposal yet? Someone mentioned an appraisal clearinghouse…
https://www.workingre.com/wp-content/uploads/2013/08/IVPI-Proposalfinal.pdf

What a great deal that appraisers are no longer able to fill out a form like this, as was prescribed by the HVCC with it’s clause that lenders could not remove appraisers from standard rotation. Gave way to a new era of predation and fictitious instantly abused appraiser performance grading.
https://www.workingre.com/wp-content/uploads/2013/08/IVPI-HVCC-SampleComplaintForm1.pdf