Is it time for federal regulation of AMCs?

Wednesday, October 1, 2014

Appraisal Management Companies (AMCs) have a role to play in the brokerage, assignment, and management of real estate appraisals. That has been the case since the 1980's at least. For some of us, beginning in that era, we likely got our start by doing work for such companies. Having worked for my mentor for a couple of years, AMCs were instrumental in my being able to go out on my own, open my own company, and begin to make a decent living in the profession. That, along with the assistance of a great mentor who encouraged me, gave me a fast start in the business.

But, over time, and through the myriad of changes brought about by government, the market, and never ending changes by the secondary market, society, The Uniform Standards of Professional Appraisal Practice, the HVCC, and most recently federal legislation in Dodd-Frank; the market, appraisers, lenders, sellers, borrowers, and just about everyone else has been left reeling. Add to that, misinformation about who can order an appraisal, who can pay the appraiser, and even who can speak to an appraiser about an appraisal, and by that we have set the stage for AMCs to envision a greater role, and convince others that they are the solution to the concerns that lenders, in particular, have about compliance.

There is a role for the AMCs and what they provide to some lenders, particularly small lenders who may not have the means or staff to set up a separate department to order and manage appraisal services. But, for many lenders, they do have the resources, the personnel, and can, if they so desire, manage appraisal services as a separate department within their institutions. Some not only do that but have created their own AMC companies as a money making department for their institution.

I certainly do not advocate or imply that AMCs should not make money at what they do. But, their service is very similar to the service provided by a real estate brokerage, more so than any other type of business. Real estate brokers work on a commission basis. That is not possible for an AMC; as such an arrangement would be unethical and illegal under most state and federal laws, for the same reason that an appraiser cannot base their fee for an appraisal on the appraised value of a property. But, the fees that AMCs charge has gotten out of hand, at the same time fees for appraisal services are cut drastically by AMCs who agree to pay the appraiser for the appraiser's services.

Dodd-Frank was supposed to clear that up. It has not. And, the fees for appraisal services vary greatly from one AMC to the next. AMCs charge fees, in many if not most cases, higher than is reasonable and customary in a given market, and compensate appraisers (who do the actual work) at rates significantly lower than what is reasonable and customary in a market. Some AMCs may charge $500-$650 for an appraisal in a market that has a customary and reasonable fee of $400 and pay the appraiser a fee of $150-$350 retaining for themselves the higher percentage of the fee, for less work than most appraisers provide in completing an appraisal. I believe that is unreasonable, unethical, and should be illegal.

I am not suggesting setting fees for anyone. I am suggesting that an appraiser should be compensated at least by 75% of any fee collected. Real estate brokers charge commissions of anywhere from 3% to about 7% for brokerage services depending on what services are provided. That is a far cry from 25% or something similar to that, that I am suggesting as fair compensation for an AMC. If they cannot survive at those rates then they do not need to be in business. But, 50%-75% of an appraisal fee that some AMCs charge for their services is outrageous, and is, in my opinion, usury.

Add to the above, that an individual borrower or seller, property owner usually has no idea that this is transpiring, and the public, society, and our free market system will and does suffer as a result.

In my opinion, the solution is either for every state to pass legislation to regulate the services of AMCs and what they can charge, and the customary and reasonable rate they must compensate appraisers by, or for the federal regulators, the Federal Financial Institutions Examination Council (FFIEC) and the Appraisal Sub Committee (ASC) be given the authority by a change to the Federal Financial Institutions Reform Recovery and Enforcement (FIRREA) act by the U.S. Congress, and enacted into law. Only with such a law in place, will there ever be a change to current practice, which I think is grossly unfair to appraisers and to the public.

Charles (Don) Clark has 41 years experience in the real estate profession as a salesperson, broker, and real estate appraiser. He is a State Certified Residential Real Estate Appraiser in Virginia and North Carolina, and is designated as a Green Valuation Specialist. He specializes in real estate appraisal, education, and consulting. Don also does peer review and assistance in assisting appraisers in answering complaints of state boards and other regulatory agencies. He is also licensed or certified to teach appraisal pre-licensure courses in Virginia and North Carolina. He holds a degree in real estate from St. Leo College, St. Leo, Florida, is an AQB Certified USPAP Instructor and has been active in the profession since 1972.

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Comments

Banks have made billions from appraisal fees over the past five years. More than enough to replinish their gambling debt.

Will AMCs be abolished? Will the sun rise tomorrow morning?

If Dodd Frank. . .in your opinion. ..has not worked, why would MORE regulation work? Our state all ready regulates AMC's. It also sound like the only regulation you are concerned about are fees. In our market, the fees paid by AMC's are at or higher then before Dodd Frank, and by state law the appraiser must be paid in less then 45 days.

Nothing is said about any of the AMCs that are not only doing review work, but are appraising properties also, mainly drive-bys and desk/field reviews (not the review checklist many of them complete). I know of at least one and they are undercutting the fees that the client would have paid the appraiser. In one instance, several panel appraisers complained to one client and the practice of the AMC completing drive-bys stopped for that one client.

Seriously? Who is currently dictating fees to appraisers? Today it's just the opposite. I've worked as a senior manager for a number of national AMC's over the past 25 years and the truth is it is not, and never has been an easy business model to succeed with, especially now with every state coming up with new hoops to jump through, bonds, fees, etc., a federal program getting rid of that nonsense and adopting consistent regulations that are easy to understand, and actually protect someone would be fantastic. The profit margin currently is very low, with clients setting fees, and AMC's fighting to make anything at all. In this current environment my firm frequently pays the appraiser MORE than the client fee in order to maintain business in other areas, as most larger clients expect national coverage, and is on the hook when the client refuses to pay for whatever reason. The appraiser always gets paid. Add in costs for expected secure computer systems and IT staff, legal staff, HR staff, sales staff, QC staff, worthless but required staff appraisers, expensive integrations, "click fees," health insurance, E & O insurance, rent, and then factor in taxes and what's left? Where is 75% coming from? Why not 80% or 90% while you're at it? Appraisal Buzz usually has good articles, but this apparent trip to the Clinton era of appraisal fees isn't one of them. How about something about appraiser education, getting rid of the ridiculous current "trainee" slave system and instead having new appraisers educated by professionals that actually understand USPAP, Fannie Mae guidelines, UAD, or even basic appraisal theory, not just what their uncle appraiser thought was important and an online test? And while you're at it, maybe recommend the government mandate the minimum fee appraisers are permitted to pay their trainees so someone with half a brain, not just someone with an appraiser in the family, decides appraising makes sense as a future career?

Echobase, you are "the problem". So, for 25 years, you have been skimming off appraiser's work/income? My guess is that AMC's spend half an hour, in taking the order from the lender, and passing it on to the appraiser, (and vise-versa) who has to spend 6 to 8 hours, actually doing the work. And how much $$ is that middleman effort worth? Way less than the appraiser gets. My 50 cents worth is.......AMC's should get about that. 50 cents. C'mon, any idiot can hand a piece of paper (electronic or hardcopy) to someone else. There is little to NO value to an AMC, other than skim off the hard work of the appraiser. After 25 years in the business, I say......Get a real job, that you actually have to work, and contribute to the process. Not sponge off others hard work.

I've worked 9 hours so far today, and still have a few to go. My typical work week is around 60 hours, managing a full staff of appraisers and reviewers, writing reports, auditing, reviewing, conference calls, as well as conducting online training, auditing QC review tools, software analysis. I wish it was easy as you assume, this is a brutal job most days, you have no idea.

Well I guess everything you said is just oookee dokee then. Have you had a vacation in the last 9 years? Because I haven't. Any health insurance? I'm a type 1 diabetic with $500 a month in medical expenses and I couldn't get insurance at any price until last year. And I bet you're not an independent contractor. So I'm willing to bet the IRS doesn't take 41% of anything you make. Still, 9 hours is nothing to sneeze at. I've been working since 2:45 this morning and it's dark outside again. I guess AMC's are screwing us both. But I think we're getting the worst of it, by a lot.

Not an easy business model to succeed with? GOOD! Chiseling other peoples' money out of their pockets, while adding absolutely nothing to the value of their work shouldn't be easy, and is far easier than it should be. If AMC's are soooooo indispensable to the lending process, then why can't you charge your own fees for it? Why do you have to take mine? I'll tell you why. It is because lenders would require you to tell them exactly what value you provide for this 'service.' And you won't be able to answer. And don't act like you care about the quality of appraisal work in any regard which exceeds covering your own backside. I've done over 4000 appraisals for AMC's. For the vast majority of these I've been asked how fast I could do it, and how little money I would do it for. I've never once been asked how good a job I could do. Oh, and you don't like fact that quality people won't work for free to become appraisers because they won't work for peanuts for 2 years. Quality people want to be lawyers even though they have to go to school for 3 years then pass the bar. Quality people want to be doctors and they have to do more than that. Hmmmmm. There must be something different about those professions. I wonder what it could be. Hmmmmm. OH! I know!!! MAYBE IT IS THE FACT THAT THOSE PEOPLE GET PAID. MAYBE A LAWYER WANTED TO BE A LAWYER SO THAT HIS TIME WOULD BE BILLABLE, AND HE/SHE WOULDN'T HAVE TO WORK FOR AMC'S WHO THINK THEY CAN WASTE AS MUCH OF HIS TIME AS THEY WANT.

Dear More Crying About Fees,

As you wrote above, you have never built a business from scratch or had the responsibility for actually paying the bills like most appraisers.

We to have E&O fees, fuel cost, car maintenance costs, equipment costs, license fees, education fees, software costs, toll costs, MLS fees, SUPRA fees, FEE COLLECTION issues, new gotcha AMC pop up fees (the most recent new AMC fee is the $5.00 Tech fee that is deducted from the reported appraisal fee). So stop CRYING to appraisers about AMC costs.

Oh and lets take a moment to discuss those AMC's whom are setting up "SHELL" appraisal companies that are paid the customary appraisal fee only to turn around and send it to a desperate appraiser at a significantly reduced appraisal fee. My state official is looking into that issue.

So you may see it as CRYING but our cry is catching the ears of OUR State and Federal representative. AMC' are making appraisers arguments very easy.

In my state we are loosing 5% of the appraisal force with only 1% coming into the profession. So with the focus on jobs State reps are starting to pay attention.

So whether AMC's like it or not the fee percentage split is going to happen........

It doesn't sound like you've been in the field much in those 25 years, echo. Yes, the figures cited in the article are accurate, not across the board but in way too many cases. I'll be happy cite those AMCs by name if you like. The point you seem to be making, is those AMCs you cite must be very poorly run. Too many of them just push paper, I can recount dozens of examples where these paper pushers never even read the reports that they are returning for revisions.
What I believe is driving the glut of AMCs, new ones seem to pop up every day, is that the only thing they sell to lenders is price and turn time, driving down prices to the point where appraisers are dropping out of the profession at an alarming rate. Combine that with the current business climate which makes it a losing proposition to train an apprentice and you can see why all of these companies are pushing IT valuation models i.e. trying to eliminate the field work from the process. If they do not sell (read that; achieve GSE acceptance) this concept, they (AMCs and lenders) will in short order have created a sellers' market for appraisal services. That is the day I stay around for.

I know it's hard to turn down business when you're struggling, but the population of appraisers is already down considerably in the last five years. If the knuckleheads would stop accepting these ridiculous fees, it would turn around much more quickly.

One thing that has always amazed me is that the appraisers and homeowners didn't hire the AMC's so why are the appraiser and homeowner's having to pay for a service they didn't solicit? If the banks hire an AMC, let them pay for it out of their own pocket! As for regulating AMC's, that should have been step one! This whole thing went from simple third party ordering service (which wasn't actually required in the HVCC) to an all out battle royale of fee's, reviews, appraisals, and on and on and on! And what gets me, is I continue to hear how most banks, credit unions, etc. can't stand the AMC's and yet they are forced to use them. And another thing that gets me, is the constant monitoring and performance reviews of appraisers by the AMC's. Really? How can someone legitimately review someone's performance without actually spending some time with them. Downloading an order and uploading an order within certain time frames and guidelines to an AMC is only one small aspect of an appraiser's performance!

I'm not complaining about the fee's per se, as they are fairly decent around here, my complaint is against the banks, etc. in general who hire the AMC's and AMC's who are not qualified and/or competent in reviewing an appraiser's work and performance.

The large lenders (Chase, Citi, etc.) expect the following: A full integration between the bank's operations system and the AMC's system, this requires 24/7 IT staff, and runs in the tens of thousands of dollars just to set up. The AMC's operating system must meet minimum standards in terms of design and security, our last system has cost several million dollars to design and maintain. The AMC must have USPAP educated staff placing orders, and all approved appraisers must be documented as geographically competent, currently licensed, with a system in place to audit their current licensing status. Every order must be tracked to the minute, with reports sent back to these big lenders showing them each milestone towards completion. Typically 90% of all orders must be completed within a set timeframe, usually 5-7 business days or 48 hours after inspection if delayed by the borrower, with written reports submitted explaining the details of any exception, and threats to reduce volume if there isn't immediate improvement. The lender provides their laundry list of QC guidelines and then audits each report for compliance with those as well as applicable Fannie, Freddie, FHA, etc. guidelines. The expectation is generally that no more than 5% of the submitted appraisals will have errors of any kind, as minor as a wrong box checked, or incomplete photo label, with again written 'action plans' required if the percentage is higher. Again if goal isn't met, the threat of immediate volume reduction or shut off always looms. Most lenders also require uploading to the Fannie Mae UCDP portal, which is a laborious manual process, and has ever changing "rules" that fire warnings the lenders won't accept, for example comments on GLA varying from public records or prior reports, further delaying the process. The lenders require tracking of all of these 'quality issues' with the results discussed monthly if not weekly, and scoring utilized to determine new order assignment. When the lender has concerns with a report, they expect the AMC to reconcile all of their questions (for free) with the appraiser, ensuring the commentary coming back is logical, complete, addressing all of their issues. These can sometimes take days to resolve, with countless emails and phone calls back and forth, especially with uncooperative appraisers in rural areas. Add in the requirements to use expensive portals, automated review software, and/or to provide each report in multiple file formats, have dedicated full time 'on-site' representatives in the lender's office, along with constant meetings and audits, which the lenders are now required to do by government regulation. Working as an AMC employee can be extremely stressful, as both appraisers and lenders don't understand the current guidelines, and in order stay in business the AMC staff must know more about everything from state and federal guidelines, FHA, FDIC, UAD, Fannie Mae, Freddie Mac, USPAP, how to appraise every property type from site condos to co ops, leasehold, condotels, underground homes, affordable housing units, you name it. Not for the faint hearted and every dollar made is earned through hard work.

You have to know everything about every regulation in the world, ok. First of all, not all AMC's know these things. For example, several of them outsource their operations to call centers in India. I've had orders for these bozos delayed for weeks waiting for a complete subject address because nobody in their ops center knew what an attached condominium is. Which brings me to the point: If you "have to" know so much regulation, then why don't you have to know anything about the subject property? The majority of my work is for people who have never been within 100 miles of the subject, yet they collect "appraisal fees" for "appraisal services" from the lender. The competency provision of USPAP says that to provide any appraisal service, you must be competent to do so, which AMC's aren't. If you are collecting fees for "appraisal services" and providing something else, you are in violation of RESPA, which states among other things that fees charged by lenders for a loan cannot not be arbitrary. In other words, If your lender charges you a fee for an appraisal service, the fee has to be for an actual appraisal service. Banks can't just make up fees. So which is it Mr/Ms Regulation Guru? Are you violating USPAP or RESPA.

Thanks Don for writing about AMCs keeping a unreasonable portion of the appraisal fee. It's a serious problem that is steadily undermining the ability of appraisers to stay in business. Not all AMCs are predatory, but many take advantage of their position as brokers of appraisal services to steal an absurd portion of the appraisal fee by targeting desperate appraisers. Right now they can easily do this since their fee is invisibly bundled in with the fee paid to the appraiser. A good first step to a solution to this problem would be to unbundle fees: require the appraisal management fee to be clearly listed separately from the fee paid to the appraiser. Then at least the rip-off would be visible.

I have, for the longest time, wondered how an AMC could even EXIST in today's business environment. By the time you hire marketing, account managers, reviewers, office staff, implement software/hardware, and maintain a regulatory model within the office, I can't see how an AMC can afford to keep their doors open. I also suspect that they are somewhat like a pyramid scheme. If an AMC gets paid BEFORE they send out the report, to their client, why does it take 30-60 days for the appraiser to get paid?? If the AMC already has the money in hand, why don't they pay up within two weeks or so? They're using tomorrow's dollars to pay for yesterday's appraisals. When does it come crashing down? I continually get orders for $290 and I turn it around and tell the AMC that the C&R fee for a 1004 is $375. I get a standard thank you note saying that they have assigned it to another appraiser in my area. Gee, what a surprise! There are single income families out there and even $290 is better than sitting home and getting paid nothing, and then trying to support themselves or their family on it. THAT'S why the low fees are still around. Some appraisers CAN'T afford to make nothing. Something is better than nothing. It just doesn't help anyone else trying to make a fair wage though. Til that changes, fees will remain low. There'll be no end to everyone out there trying to make a living off the appraiser's backs. They're adding value so let them add to the overall fee, not just take some of ours! Time to get real.

AMC's rarely get paid before the report is done, usually it's months later, even from some of the bigger lenders.

I fired "VALUTRUS" when I found out that they were skimming 33% of the fee charge for my services.
They initially charged a homeowners credit card $1575 (they ran his card three times). So they were charging $525 for the
appraisal. Offering me $325 for my services. This is more than the "sharks on the street charge for the "Vig"".

There are two key concepts at the core of debates surrounding the need for gov't to step in to control prices in some manner. First, is a purely consensual economic relationship between the parties inherently unfair to either party? And second, do free markets actually work?

When it comes to entering into a transaction for appraisal services, shouldn't either party be free to say "no thank you" to a fee that is unacceptable to that party? It would seem that the buyer and seller of a specific appraisal assignment would have the best information to determine whether a fee is unreasonable or not customary, than would be accomplished by a blanket regulatory decree from parties with no knowledge of the specific transaction.

So do free markets work? If the fee is truly too low for a given assignment and the local market, then the buyer of the appraisal services won't likely be able to find a seller of appraisal services who doesn't say "no thank you", and thus, will have to raise their bid until they fill the order. Furthermore, do free markets work when it comes to fees charged and paid by AMCs? Purchasers of AMC appraisal services (lenders) are constantly being solicited by competing AMCs. The main drivers for lenders in their purchasing decision are price and quality. If certain AMCs charge "too much", that leaves the door open for competing AMCs to take their clients based on price. And, if the quality of the services of certain AMCs is too poor, then that also opens the door for the competition.

The real issue is appraisers easily find trainees willing to work for near, if not, nothing. But once these new appraisers have enough experience, they are horrified to find them out in the field, competing with their "mentor," thrilled to take $300 for an order they were previously forced to do for $50. So who gets the blame? A-M-C.

I'm just going to paste what I added to the AMC apologist above: Oh, and you don't like fact that quality people won't work for peanuts for 2 years to become appraisers. Quality people want to be lawyers even though they have to go to school for 3 years then pass the bar. Quality people want to be doctors and they have to do more than that. Hmmmmm. There must be something different about those professions. I wonder what it could be. Hmmmmm. OH! I know!!! MAYBE IT IS THE FACT THAT THOSE PEOPLE GET PAID. MAYBE A LAWYER WANTED TO BE A LAWYER SO THAT HIS TIME WOULD BE BILLABLE, AND HE/SHE WOULDN'T HAVE TO WORK FOR AMC'S WHO THINK THEY CAN WASTE AS MUCH OF HIS TIME AS THEY WANT.

IMHO the core issue is that market volumes of appraisals being ordered has dropped by over 50% in the last few years, yet the number of appraisers in the industry has not dropped commensurately, thus there is a lot of pain being felt by falling prices due to the demand/supply imbalance. With that pain, there is anger which is directed at AMCs or the "knuckleheads" who are willing to accept fees that are "too low".

If lenders constantly shop AMC's, which do you think they'll hire, the one that will get them the highest quality appraisals, or the ones which will blacklist appraisers who don't make the appraised value they need?

Lenders typically want to get the best quality and service for the money to best serve their customers, the borrowers. Plus, they have to make sure they manage risk and stay in compliance. Should either party be forced to do business with another party? Or, should should either party be forced to pay or accept a fee that is unacceptable to one party?

This is why I have dismissed most AMC's I used to work for. Most of my work is directly for banks where I get a much higher fee. I will not do any appraisal for less than my normal fee. And I don't have the 20 extra pages of garbage they want added in for free.

AMC's have PROVEN to be nothing more than a parasite on the entire lending industry. Especially to the consumer and appraiser.

While earning millions per year off the backs of appraisers and robbing local tax bases of income... Most have proven to be just owned by the lender and being used for additional "profit margins:. They do NOTHING to provide more credibility or accuracy of reporting data, only spell checking and extra redundant data.

Rogue appraisers have always omitted and manipulated comp data to "make the deal work". How do AMC's check for manipulate data??? AMC's shop for the cheapest people they can find and do NOTHING to create more credibility of the data... only that it "fits" FNMA guidelines or what they call "lender requirements" which the rogue appraisers gladly manipulate the data now to get past AMC "reviewers" instead of just "hitting the #".. It's all still fraud and BS.

Since HVCC and Dudd-Fwank I have yet to be asked for any credentials before accepting an assignment other than "Fee and Turn Time". That is the ONLY requirement requested from an AMC.

The only fix at this point is to Federally mandate that appraisers are selected on a rotation basis with a limited geographic competency such as the VA model. The rotation panels should be managed by the states and state regulators should be held ACCOUNTABLE for the panel. Anyone caught cheating or manipulating data is KAPUT.

There were plenty of rules in place before HVCC and Dudd-Fwank - but nobody was enforcing them. So now State-Certified appraisers with 20 years of experience suddenly need to be "managed"??? Why??

As a 20+ year veteran all I ask for is the ability to tell the truth and say no when needed and not get fired for doing so.
Why is that so hard?? Because appraisers are individuals and we are being played... We were played by the Mortgage Brokers in the past - and now the AMC's. It is time for this madness to come to an end - PLEASE!!!

We HAVE to agree to the rotation panel model just to bring credibility back to Real Estate, to bring appraisers "together" so we can bring consistency to reporting which is also a real issue. We need to be forced to work together instead of being played against each other for the "lowest fee and turn time". We are nothing but slaves to this system and as for now "There is NO Reality in Real Estate".

Appraising is not that complicated... we don't need extra data and new ways of doing things.. we only need the ability to report an honest opinion and to be assured that we will be supported for doing so. AND- that anyone caught cheating will be HELD ACCOUNTABLE like any other so-called profession..

But that's just my opinion, I could be wrong.

So here we go again AMC / Appraisers upset with the current problems but no one has come up with a solution or coarse of action to solve the problem. The responses are always the same. This site does nothing more than preach to the choir. Yes, we need a change.
So if no one is happy then lets do something. Your vote counts. The time has come to unit the poor. Explain to me how the Federal government can fine banks billions on dollars for faulty loans and still be in business? The banks had their own appraisal departments and now we need to deal we with third party companies who are former appraisers who could not survive under the current regulations and they are still complaining. Appraisers who took it up the ... are still doing the same thing. The coarse of action is clear .. step up, unite. So how do you unite the independent business owner under the capitalist society-read Genghis Con - we all share in the profits or pillage.

Thanks Don,
This was a well written article which echos the concerns of the vast majority of Appraiser Professionals still left in the business. I would like to provide my input into what I believe to be the "ONLY" true solution to this problem. As I see it, the gripe that most appraisers have(including myself) is that AMC's were literally handed the keys to the VAULT, when the poorly misguided HVCC was adopted by FNMA as a means for Fannie to escape a nasty class action lawsuit. This adoption by FNMA stripped the hard working Appraiser of the "right to do business" directly with the local clients he/she had developed over the years, while simultaneously directing the flow of the vast majority of Nationwide appraisal orders directly through AMC's, without any regulation in place as to who these AMC's were and what their business model was(can you say WILD WILD WEST). We all remember the AppraiserLoft's of the world and the damage done! Now, these money drunk AMC's are waking up from their 5 year windfall of profits, to find State regulations & perhaps Lender regulations in place that are slowly eating away at those profits(tisk tisk). However, the real 800lb Gorilla in the room, is the fact that there is still no regulation requiring the AMC to disclose their own management fee on a seperate line of the HUD-1 settlement statement. This is the AMC's last line of defense, this is the cloak they have all been hiding behind! How is it not defrauding the public, when a borrower thinks that his/her $500-$600 is going directly to the Appraiser that inspected their home? With all of the "disclosures" required of Lenders, Realtors & Appraiser's, how is the AMC's management fee still exempt from disclosure to the public? It really is that simple of a solution, and here is why; As soon as a borrower reads "Appraisal Management Fee $250" on their HUD-1, they will ask the question "why this is their responsiblilty to pay?" And the answer is clearly that it is "not" their responsibility to pay, because this is a service provided to the "Lender" with absolutely no direct benefit to the borrower! Therefore, in the end the Lender will end up being responsible to pay the AMC for this service, which undoubtedly will eventually lead to the demise of the AMC model....
In today's day & age of extreme over-regulation, allowing AMC's to continue to "hide" Billions of dollars worth of profits behind the "Appraisal Fee" designation is an absolute travisty!!!!

Where did you get your data to sight a $250 Appraisal Management Fee? I work at an AMC, and our management fee is in the $50 - $75 range. Several states have AMC laws in place that explicitly state the appraiser and AMC fees need to be segregated, and many more are creating addendums to current laws to include this. After staff, QC staff, technology and overhead, breaking even is a challenge.

There is a massive amount of misinformation out there regarding AMCs stemming from some long gone bad eggs that poisoned the well. The notion that an AMC sits on a pile of cash reserves and billions in profits is simply preposterous. Most operate on an extensive line of credit in efforts to pay the appraisers faster because lenders take on average 6 weeks to pay the AMC for their services.

The notion the AMC is hiding being a veil to hide fees is simply not the case where I work. We welcome a standard fee schedule that could be followed by all parties involved, paying the appraiser what they should be paid, the AMC what their services should be paid, and forcing the lender to pay a C+R fee per the spirit of the Dodd-Frank Act.

The AMC that you work for is hoodwinking you as well as borrowers on the HUD-1. Nearly all AMCs are billing $500 to $600 for appraisal orders (because they can) and paying $225 to $275 to the appraiser. I suspect that your employer is drugging you. Stop using the company water cooler and you should begin to see the real world within 4 to 5 weeks.

With all due respect, you can plug in "any" figure you want($75, $150, $250) it doesn't matter, and your missing the point. If the AMC that you work for is "doing the right thing" then I applaud your firm for doing so. I myself work with only a couple of AMC's on a semi-regular basis, because I have found them to be fair & trust worthy. However, the vast majority just simply are not, which is why there is so much "hatred" in the voices of the Appraiser Community when it comes to the AMC model of doing business. The point I am making is that once the Appraiser Fee and the AMC Fee are required to be seperately diclosed on the HUD-1, there will be no more incentive for the AMC to attempt to drive down the Appraiser's Fee, beacuse the AMC will no longer be able to hide their fee within the Appraiser Fee line on the HUD-1. If the AMC needs to make $150-$200 per file to be profitable, then ask the borrower to pay. If they pay you are in business, if they don't you are out of business. That is known as "Free Market Capitalism". But "taking" from the Appraiser what he/she deserves to earn, and hiding it from the borrower is not only dishonest, but it should be illegal.
I honestly believe that once the AMC fee is completely seperated from the Appraiser's Fee with no ties what so ever, that these two businesses can thrive together. AMC's will be able to seek only the most qualiified & experienced Appraiser's, paying them what is truly reasonable for their expertise($400+), and the AMC's can charge whatever the market will bear for their services, and the Appraiser's will not care what the AMC is charging because it is not coming from their hides. I can't imagine that you or anyone else who has any integrity what so ever could possibly argue this POINT!

The only fix at this point is to Federally mandate that appraisers are selected on a rotation basis with a limited geographic competency such as the VA model. The rotation panels should be managed by the states and state regulators should be held ACCOUNTABLE for the panel. Anyone caught cheating or manipulating data is KAPUT. - See more at: http://appraisalbuzz.com/buzz/features/is-it-time-for-federal-regulation...

I would disagree let each state handle the AMC's. There is to much political influence at the Federal Level. Make the AMC's deal with each state.

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After our mishap at guess factory Mannheim, my abercrombie uncle mulberry and I made for the Duchy of X——. The reader may find out the place easily enough; but I do not choose to print at cheap jerseys full the names of some illustrious persons jordan shoes in birkin bag,hermes belt,hermes handbags,hermes birkin,hermes bags,birkin bags whose society air jordan I then polo ralph lauren fell, and among ray ban sunglasses whom I was made the sharer in a very strange and tragical adventure.

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