Customary & Reasonable

Wednesday, March 5, 2014

Customary & Reasonable fees were all the buzz back in 2010. Then the conversations subsided. Appraisers had a whirlwind of refinance activity to distract them for a while. When interest rates ticked up, volume plummeted. Now every dollar counts more than ever. The sting is especially painful when volume has dropped precipitously and fees were cut simultaneously. That spells double trouble.

With the signing of the Financial Regulatory Reform Bill on July 21, 2010, also known as Dodd Frank, there were significant changes that affected the appraisal community.

Title XIV addresses appraisal fees:

CUSTOMARY AND REASONABLE FEES

Lenders and their agents shall compensate fee appraisers at a rate that is customary and reasonable for appraisal services performed in the market area of the property being appraised. Evidence for such fees may be established by objective third-party information, such as government agency fee schedules, academic studies, and independent private sector surveys. Fee studies shall exclude assignments ordered by known appraisal management companies.

Essentially Dodd Frank states that C&R may be determined by three methods:

  1. Government Fee Schedule
  2. Academic Study
  3. Independent private sector surveys

The great news is that every stakeholder has expressed renewed interest on the topic of C&R. Regulators, lenders and AMCs all want to know what is both customary and reasonable. Clearbox LLC recently updated their fee survey tools allowing appraisers to enter their fee schedules for free. And even better, once registered the appraiser can view the average fees for their coverage areas.

Clearbox has overlaid the VA fee schedule and has also engaged Roger Staiger III, adjunct professor at Georgetown University to perform an academic study. But first Clearbox is inviting you to input your data. That is why it is free, of course. Without your help it will be difficult to enforce C&R.

On the client side, they get a pretty nifty tool where they see an array of every county in the US with every GSE form. The general population is shown for each county along with the appraiser population for the county. The ratio of appraisers per population is pretty interesting all by itself. Then the mean, median, and mode is displayed. If you are a lender or AMC and wish to see a demo contact sales@clearbox.com.

Clearbox needs your help in making this issue viral. If you belong to a state coalition please spread the word. If you belong to a local chapter of a trade association please engage your peers. Without access to data, enforcement has less of a chance of occurring.

To enter your fees just go to www.clearbox.com and select "Sign Up". The next step is to choose the Basic Option and begin entering your fees. Thank you in advance for your participation in the fee survey. Your input matters!

Have any comments or would you like to submit content of your own? Email comments@appraisalbuzz.com.

Comments

No profession could survive what appraisers have gone through. Even doctors (Before Obamacare) were getting run over by the insurance companies, then medicare and now Obamacare. During these times appraisers were actually making as much money as most family doctors. The doctor profession is very expensive to get into and is not as lucrative as it used to be. (Sound familiar?)

The appraisers have followed a similar path. We are getting thrown under several busses and very few are on our side. The AI, HUD, FNMA just don't care. AMC's don't care, and the lenders, realtors and homeowners don't care. We have too many battles to fight, and we have a long history of losing all of them. But you make a simple mistake on an appraisal, or don't come in at "Value" all im a sudden some of these entities care.

The only option most appraisers are told, is either do non-lender work or stop working for AMC's. If you could control 95 percent of appraisers, you might be able to do that, but look at the strongest unions . . . even they cannot get over 80 percent to participate in a long term strike. How are appraisers going to get 95 percent to boycott AMC's? They are not.

Most of us are just biding our time until we can retire.

Before AMC's......I said to anyone who would listen that Until the Appraisers together in unison refuse to accept appraisal assignments for 24-72 hours we would always be akin to field hands in the south. After AMC's and the HVCC thanks to Gov Cuomo (no comment) it has become worse............Yes , we are our own worst enemies, "We have met the enemy and they is US"....IN 1917 Russia, the rallying cry was "Workers of the world unite"... NOW IT SHOULD BE..."Appraisers of the world Unite" but we won't because there will always be some SOB who wil accept a lower fee..........and screw it all up for the rest of us............."A convicted muderer has more rights than an appraiser who has had a complaint filed against him to his/her State Board...DODD/Frank..two reprobates can be thanked for some of the current state of affairs....................

The main problem that I see with C&R is that appraiser fees are not so simple. My company is in an area that has many different property types and geographic complexities. We cannot give a fee to a client based on what form we will use; because, most of the time, the fee will be wrong. My fees are based on a complex rubric with more than forty categories of complexities and other factors that influence fee. Everyone in this industry wants to standardize fee down to a form. That is silly and makes it more difficult for appraisers to negotiate a fee based on the job. We're expected to set one fee and take the good with the bad when easy jobs take half the time or less than the harder ones and come with far less liability or competency requirements. I see fee schedules as the fundamental problem with C&R and it is why fees will never be fixed in this way.

I have had a stance on this topic for some time now, however my views most often fall on deaf ears. For the most part Appraisers have left the determination of C&R up to the lenders/AMC's. This is crazy, in what other service industry do you hire a company (if you are an independent contractor you are a company) and tell them what you are going to pay, in addition what company takes that and amount to base the Customary and Reasonable fees on? None that I know of. Also in this whole mess it seems as customary and reasonable has been all jammed together as one title with only one meaning. Most in the industry has over looked the little word AND. Just because some people are choosing to do appraisals for a fee of $XXX, does not automatically mean it is reasonable. I am sure all of us have done something in their lives and said "this is not worth it" but you go through with it for some reason, may be just to get by for the time being or may be to keep your word. No matter the reason what you have done is not reasonable compensation. Now if a number of people are doing if for the same or similar reasons the compensation is now customary, but it does not automatically make it reasonable. Appraisers really need to learn how to analyze the cost of doing business, the income being made analyze that to the hours being spend for the money left over then see if the payment is reasonable. If so fine, however I would imagine that most will come up with a figure of far less than what they think their time is worth. Please keep in mind this is supposed to be a professional field and the fees we earn should be professional fees.
In addition when calculations of the "C&R" fees are completed by large companies only looking to benefit from discounted labor rates they all seem to want to apply averages. Fees for a service such as appraisals should not be calculated into averages, each assignment should be analyzed and the fees should be based on the scope of work required for that assignment. This means getting the engagement letter up front analyzing the request, modifying the engagement to terms agreeable to the appraiser then supplying estimate. This is something that appraisers in my area fail to do, and the only information asked for on the call from the AMC is how much and how fast, then the response, we've called 4 other appraisers and they are cheaper. If you happen to get the order the engagement letter comes over with a bunch of additional items that you did not agree to. Such ad a minimum of 5 comparables, physical photos of comparables and the cost approach developed no matter how irrelevant to the assignment it is. Do you think the quote may have been different if you had this information up front? All of these "additional" items should drive the reasonable fee up, as they all cost time and money. Now because we are trying to keep our families fed, we make a business decision to do the assignment and now that fee gets thrown in the pot and drives the average down, this average now gets calculated in to C&R, no where in the process is the fee reasonable. Don't forget about the AND.
Lets not leave the fee calculations to companies such as Clear Box, AMC's or banks, if you really think about it, what motivation do any of them have in paying a fair fee? None, they all just want in your pocket in some way or another.
I feel the only way to make progress on this front is to unite some what, if most markets were made up of small to mid sized groups of appraisers (3-20) we could all benefit from increased fees, and better quality reports as we could all draw off each other experience. Appraisers should not view their peers as a threat or enemies, they should be viewed as friends and allies.

You couldn't be more correct Lonnie. All the AMC's do is call around to find the cheapest appraiser so they can make more money. Do you really think the "cheapest" appraiser is the best or just the most desperate? In addition, the AMC's fee is not disclosed on the closing statement (at least in my state). I've actually had homeowners ask me if I was enjoying my raise because they think I'm getting the entire amount listed on the closing statement. So much for "truth in lending".

I have an idea -leave residential appraising. I used to like this profession (I no longer call appraising a profession, it's a job... appraisers have licenses for lenders to exploit). I dread my job, every single day I loathe getting out of bed -to go battle traffic, come back to office to answer emails, make phone calls, appease AMCs and clients w/ ridiculous clarification requests. I take SO much pride in my work, spend hours, days on an assignment... then I receive an email blast for a $350 3-Unit, FHA 203K assignment, I started actively seeking other means to make a living.

Residential appraising no longer belongs to appraisers my brothers and sisters. Residential appraising belongs to the AMCs, the lenders, and the cottage industries like Clearbox that spring-up as a result of Dodd-Frank (which in theory I believe was well intentioned).

If you can hang on another 5 years or so, maybe Residential Appraising will belong to appraisers again. This will take time, we will need another market correction, and buy-backs aimed at license discipline for the "fast and cheap", boilerplate appraisers, working for peanuts will first need to occur.

In the meantime, maybe take a job at a Taco Bell? My State's coalition doesn't care about small shop appraisers like myself. The big players in my State's Appraiser Coalition all own their own appraisal firms. They dislike AMCs for entirely different reasons than the little guys (the big players in most state coalitions dislike AMCs b/c AMCs take away their prospective pool of work horses). Whats the difference between a larger Appraisal Firm (splitting fees), and an AMC? Not much...maybe a more thorough review on a local level, but that's it).

Oh, why would I want to enter my C & R fees into a website Clearbox? First, Im insulted by the concept of "background checks"...INSULTED beyond words! My license, and subsequent renewals are my back ground checks! The ASC website is my background check. My State's Licensing website is my background check. What exactly are Clearbox clients worried about? I'm pretty sure if you break the law, most states discipline, suspend, or revoke one's license.

I can't wait to see today's, broadcast, slop orders. Anyone else notice AMCs are now taking 60+% of the loan applicant's total "Appraisal Fee"? Ugh.

Nobody cares about the housing market. It's finally turning around and now we hear rumblings of the sub-prime market making a come back. Just wait until these sub-prime loans go bad -the fast & cheap appraisers will cost their lenders & GSEs billions, trillions.

You get what you pay for. My C & R fees will always be overlooked by most AMCs b/c there is no incentive to pay me more for my expertise. Rels is concerned with their bottom line, for eg., not quality.

I abhor what the "Appraisal Trade", (not a profession in my eyes), has become.

I only hope that other appraisers see as clearly as you my friend. I too dread this job each and every day and carry on with my head held low until the day I can fully transition to an actual profession with legitimacy. Appraisals have become a joke and commoditized, any idiot that can read the 14 page AMC engagement letter can produce a quality product, right? Between appraisal firms ( read: sweat shops) and AMCs roughly 70% of the available appraisal transactions are low dollar. What other industry accepts increasing workload demands and lower pay year after year? And year after year I witness appraisal 'reform' that merely results in more complex ways to fill a form while appraisers are criticized for being form-fillers. Most back-asswards reform I have ever heard of.
These senior appraisers should have the integrity and dignity to become leaders and advocates for the profession rather than oppressors of their peers. The new opportunity in the appraisal business seems to rest solely on the creation of fear & loathing for the purpose of selling the appraiser some unneccesary product or service in the hope their business will miraculously be revived.

No background check is provided with the free version of Clearbox. If you would like to enter your fees and see the fee survey for the territories you cover you can do so by signing up for the free version. You will not receive a background check unless you chose to upgrade to the premium version of Clearbox.

If you hate your job life is short it is time to leave the business and live life. I believe as there are less and less performing the work, the fees will increase. Supply and demand; wait a minute is that something in appraising?

What a wonderfully and creatively crafted response Phillip Goodrich. I am always delighted to know that my peers excel ( or are at the very least proficient) in the basics of the English language. Skills such as grammar and punctuation are entirely overrated. On the bright side, at least the appraisal licensing boards are revising the entry level education standards.

I cannot believe the number of appraisers that are charging the same fees that they have charged for 10 years. I see fees of $300-$350 and they have been the same for years. Appraisers that do this are a thorn in the side of those of us that actually produce a real appraisal. I review appraisals and cannot believe the laziness and sloppy work that is being submitted. Most appraisers in my area are also Realtors so they are really only part time appraisers and it shows. I think that in order to bring this profession out of the gutter appraisers should not be practicing Realtors/Brokers and vise versa. I am in an area that is very difficult in which to perform an appraisal and do not have a "set" fee. My fees are based on the scope of work and nature of the property. This is reasonable. It is not reasonable to simply state a fee across the board and think that you can be profitable. If this industry is to actually be a profession then the professionals within need to act and perform like professionals. I review appraisals that have had the same canned comments for years. When reading most appraisals you are unable to tell if you are reading about a mobile home or a mansion. Maybe if we had full time professionals that actually perform as such the fee issues could be resolved. But as long as the low bid gets the order we will continue to circle the drain as a profession. Those that have not adjusted their fees despite the fact that an appraisal takes hours and hours to produce need to get out of the business. After all, how many prices have remained the same for our goods and services for 10 years? I cannot believe that we have to have this discussion in the first place. No other profession has these issues because the professionals within other industries state their fees and that is the fee. This should not be a low bid auction people! Either make you fees compensate for your time, experience and costs or get out of the business. I do not see other professionals that require the time, education & effort that becoming an appraiser entails throwing their businesses down the drain. This problem would resolve itself without the need for the government to set our fees for us if the part timers would pick a hat or leave the industry and leave those of us that treat it as a profession to make it a profession and to make a living doing it. We should not have to be the benevolent society for AMCs.

I am a real estate broker as well as appraiser. I am a full-time appraiser and a part-time real estate broker. I inform the people who work with me that I am part-time broker, and if you are looking for a high profile real estate salesperson and want me to show you 30 houses it is not me. I like the idea of looking at houses that are actually listed and when they sell disclosing through an appraisal their true condition. There's a lot of puffing and the good appraiser will wade through the crap. You are so correct there are appraiser's that do not adequately describe the property or comparable. I have had residential real estate appraisals that can be as many as 50 to 60 pages. It may be an overkill but I will tell you if you are reviewing my work it will take you a while. You will earn your $300.00 reviewing me. However I have not charge $300 for an appraisal in so long I don't even remember when it was. My fees are reasonable and customary are between $400 and $600 for residential. I agree with you, and fees should be based on each request. You might be able to have a standard fee if you are in a cookie-cutter subdivision and perform work there all the time. It is just my opinion like each an appraisal is that appraisers opinion.

It always interest me to hear people comment about reasonable and customary fees. If appraiser's really perform their job and doing what is true appraisal analysis for lenders they might want to do an appraisal on their own assets. It makes me question the integrity of some appraiser's if they do not feel there making enough compensation for their work. I have been steadily raising my fees because I believe what is reasonable and customary is what is necessary to run my business. If I do not feel like I'm being compensated in a fair manner I turn the work down. If you are feeling this is the only thing you can do and you are willing to work for minimum wage or less you should be out of the business because you are not a qualified appraiser. Do an appraisal on your own business. So you people whine and cry because you are not making enough money maybe you are getting paid what you are worth. So it is about time a professional appraiser appraise themselves before the appraise for someone else's. Just food for thought; I can tell you if I could make more money working in a fast food restaurant or being a sales person in a department store what makes you think I would be an appraiser and take the risk and liability of operating my own business. This is nuts you are in control of you, and you should take responsibility for your business. Once again be in appraiser. It is what it is!

I just have a simple question, what would you do if you raised your fees, and as a result you got no work?

1) Lower fees
2) Get a job at McDonalds
3) Retire
4) Live off of wife income

Please answer, because I see many appraisers say the same thing you do, but none will tell me what to do with the results of your actions. I know in some markets appraisers can raise fees, but in other markets, they starve if they try to raise fees.

I knew that as soon I heard "customary and reasonable" is was a big fat lie. It sounds like politician speak. Louisiana has passed bill that established a reasonable fee base for there appraisal products in their state. We should do the same. At least it will create a basic starting point. We may be able to have a starting fee at what I was making 20 years ago. Louisiana did not do too bad.

The real problem is AMC companies have been piggybacking on the appraiser fee for the last few years. We need to demand a separate fee for the appraiser in the HUD-1 and thus communicated to the borrower and agent what the appraisal fee is and what the AMC fee is. You have many AMC companies that make far more than the appraiser in many deals for far less work. They have established a non-competitive business in many cases as lenders establish what AMC the borrower will go too. This is not a fair business practice under our laws. The borrower should not be forced to utilize a specific AMC just because it is fully paid by the lender. A credit should be made so the borrower can go anywhere with that money he chooses. It has been a large scam create by the largest banks in order to control more of the fees from the lending process. We as a group need to force the lenders to comply with state and national laws that provide for an open and honest transaction in the lending field. The national politicians have been already bought due to a recent release of a ruling that allows the lenders to have an option of disclosing the fees paid to appraisers. This should not be an option unless the appraiser is a direct employee of the AMC company. Bug your state representatives to further fair business practices in each state. The big banks can't buy everyone. It takes work and time I understand. I hope we can change this fraudulent business practice. Without choice good AMC companies will be forced out of business. Agents and borrowers will be upset if their deal gets screwed up by a $200 appraisal. Especially if the AMC is making $300. Sound familiar. God bless appraisers.

...but as long as there is a bottom feeder or 2 to undercut everyone, it makes no difference. To the AMCs, C and R is whatever the lowest bidder is willing to accept. The answer is hold firm on YOUR C and R fees, and let the AMCs pound sand unless they pay you what you need. The system may never change, but at least you wont resent the few clients you have left.

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