An Evolving Symbiotic Relationship Between AMCs and Appraisers

Monday, August 11, 2014

As a former appraiser with nearly 30 years of experience and now an executive working at an AMC, I have observed a true evolution in the way appraisers and AMCs work together. The relationship between AMCs and appraisers started off unsteadily but has improved over the years. It has now reached a point of mutual respect.

Respect is a critical component in today's market as AMCs and appraisers have a somewhat forced interdependent association. While there is always room for improvement, AMCs and appraisers have seemingly cracked the code when it comes to working with one another. Consequently this has resulted in a healthier and much smoother appraisal process. While the relationship has come a long way, there is still some unnecessary tension that must be eliminated in order for both parties to collectively reap the most benefit. In effort to continue to improve the working relationship between AMCs and appraisers, we must seek to understand one another's key roles and responsibilities.

Working from both sides of the coin, I am in a unique position to have personally experienced some of the struggles and concerns that surface from both the part of the appraiser and the part of the AMC. The root of all tension in this business is misunderstanding. When appraisers and AMCs fully appreciate one another's importance to the overall appraisal process, a more harmonious working relationship ensues.

Think about this analogy: appraisers are to AMCs what reporters are to editors. Appraisers are in the trenches, taking pictures and collecting all the facts needed to make an accurate valuation. AMCs must review, proof and edit the hard work of the appraisers, ensuring a thorough appraisal has been produced to reduce errors and avoid timely requests and corrections from the underwriter, who in this scenario would be the publisher. Quality AMCs are in business to enhance appraisers' income with less hassle by streamlining the appraisal process and giving the client an acceptable final product in terms of high quality and limited conditions. Appraisers should understand that any revision requests coming from an AMC are client-driven and are not requests from a QC reviewer or an excuse for a power play.

One misunderstood aspect of the AMC/appraiser working model is fee sharing. Appraisers rightfully feel a sense of ownership of their appraisals. After all, it is their hard work; they did the heavy lifting when it comes to producing an accurate valuation. Therefore, they feel they should be compensated in full for their work and do not understand why they have to share fees with an AMC. What many appraisers do not understand is that AMCs have to pay several thousands of dollars in compliance fees in order to keep their business running and provide qualified and compliant information in response to increased lender rules and regulations. AMCs are fulfilling an industry need that has been mandated by legislation, and they too experience heavy cost burdens brought on by today's environment.

Sadly, another cause of tension is that some unprofessional AMCs neglect to pay their hard-working appraisers on time. AMCs must always give the appraiser or lender a specific timeline of when to expect payment. Professional AMCs pay appraisers within 30 days of the completion of the report. Anything beyond 45 days is simply unacceptable.

The AMC needs to respect the appraiser's position and treat them as the professional experts that they are. When working as an appraiser, I recall some AMCs treated me as though I was a rookie in the industry despite my 20 years in the field at the time. There was no reason for that. When AMCs treat appraisers with the respect they deserve, appraisers will return that respect and produce better work.

Both appraisers and AMCs have specific jobs to do, and when one of us fails to do the job, the other has to scramble around to compensate. If everyone fulfills their responsibilities as expected, the process goes smoothly for all involved. AMCs provide appraisers with tools designed to make their jobs easier, but it is up to the appraiser to take that step and utilize these resources. For instance, AMCs have developed proprietary integration hubs that link their mortgage lending and servicing clients with local appraisers to speed up the process of delivering appraisals and to improve quality control so that fewer reports need to be returned for corrections.

It is a highly symbiotic business relationship. Appraisers are a reflection of the AMC, and vice versa. Appraisers are crucial to a good customer experience in any housing transaction as they are one of the few people that the point of contact meets when a full appraisal is performed. Therefore, the appraiser is not only representing himself/herself when they meet the point of contact, but also is representing the AMC and the lender; understanding this is very important to all parties involved. We all want to leave a good impression.

I am happy to see progress being made in terms of AMCs and appraisers working together. Both parties should continue to cultivate, enrich and protect the mutual respect and appreciation for each other.

Scott Pickell is vice president and chief appraiser at LRES, a national provider of residential and commercial valuations and asset management for the mortgage, banking, credit union and real estate industries. For more information, visit http://www.lres.com.

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Comments

"One misunderstood aspect of the AMC/appraiser working model is fee sharing. Appraisers rightfully feel a sense of ownership of their appraisals"

- THEFT OF SERVICES I.E. STEALING 30-50% OR MORE OF THE ACTUAL, APPRAISAL FEE CUSTOMARILY PAID DIRECTLY TO APPRAISERS IS ILLEGAL UNDER RESPA, TILA, AND CONFIRMED BY DODD-FRANK 2010.

"AMCs are fulfilling an industry need that has been mandated by legislation"

PATENTLY FALSE ASSERTION. STARTING WITH TITLE XI 1989 - AND IN EVERY FEDERAL LAW AND BANKING REGULATION GOVERNING APPRAISALS - UTILIZATION OF EITHER A CAPTIVE-OWNED SUBSIDIARY OR "INDEPENDENT" THIRD PARTY AMC - HAS BEEN, IS, AND CONTINUES TO BE - ENTIRELY OPTIONAL.

I have heard that there are now only 100,000 appraisers left and dropping in US and territories. Permalink has said it, the profession is a joke when you work for an AMC. A management company that has no real function or purpose so they spend their time nit-picking and harassing appraisers and then extort money from them.

could write anything good about amc's. The only good amc's is one that has gone belly up and owed every appraiser that they have done business with. I have now taken 2 amc's to small claims court to get paid. I have won both times. The last one then filled a compalaint with the state appraisal board. The board did nothing, but it just goes to show you what a snake some amc's are. I have only done business with amc's which are near me, generally one state away. The rest I turn down as the state i live in, South Caroilna does not have any requirements for amc's. I still only do work for them when I have nothing else to do. My local clients which most still deal direct with appraiseres are my best clients and get the best service from me. I'll be surprised if Appraisal Buzz prints this, they hate negitive comment against amc's.

In my experience AMC's are just a third party with their own set of comment requirements getting in between the appraiser and the client causing extra work for less pay!

Symbiosis is defined as a relationship between two people or groups that work with and depend on each other. Implicit in your thesis is that, prior to the advent of AMC's, appraisers were incompetent and incapable of providing services for their clients. In fact, what occurred is that AMC's inserted themselves into an existing symbiotic relationship between appraisers and clients that had served the industry well since the 1930's. Nothing of value has been created, other than an additional profit center for the lending industry at the expense of appraisers. Appraisal reports are no more accurate than before. By demoting and isolating appraisers from their clients many have simply left the business: potential mentors, instructors and supervisors lost forever. Vast human and intellectual resources have been tossed aside. New recruits are now groomed and critiqued by an AMC fulfillment center across the country or across the globe. Competency has taken a back seat to compliance. The regulatory Medusa's head has merely created job opportunities for AMC's and regulators at the expense of appraisers.

Is the safety and soundness of our financial system better off? Are loan portfolios of superior quality today, than 15 or 30 years ago? What is the AMC industry doing to recruit, train and ensure competent and qualified appraisers enter and remain in the business as a viable career? Adjusted for inflation, appraisal fees are at levels of 30 years ago. How are AMC's acting on behalf of appraisers?

The term "Management" (the "M" in AMC) implies a set of fiduciary responsibilities to both the client and the appraiser. Many AMC's now claim they are merely pass-through "facilitators", or portals. Perhaps it would be in order to replace the "M" in AMC with "F" for fulfillment.

AMC's wrought destruction on existing appraiser-client symbiotic relationships. As many appraisers have now been reduced to "non-profit" status, I would suggest AMC's take up the same model and redirect profits back into training, recruiting and paying for competent appraisers . . . the only participants required to "promote and preserve the public trust."

Charles Baker, SRA

I could spend all day arguing with this article, but I'll just touch on a couple of things:

First, a symbiotic relationship in they way you refer to it would require both parties to receive some value from the other. In fact the AMC/Appraiser relationship is purely parasitic. Appraisers continue to perform the work that we have always performed - appraisals - but now we have a voracious second mouth to feed, one that often takes half or more of our life's blood while urging us to go ever faster so it can have more, more, more. In return we get nothing but frequent headaches and chronic financial anemia. The lender gets benefit from the AMC's existence...but they aren't the ones getting drained, are they?

So your justification for taking some/most of the appraisal fee appears to be "We have bills"? Really? Have you ever heard a single appraiser suggest that AMCs should not charge a fee for their contribution to the loan process? No one expects you to work for free. We just don't think the management fee should be subtracted from the appraiser's fee. It should be *separate and in addition to* the appraiser's fee. Appraisers should be paid C&R and the AMC's fee should stand alone. Not only would that solve 90% of the hostility between appraisers and AMCs, but it would remove the incentive for AMCs to engage the cheapest appraisers they can find (and that includes the staff appraiser model) which starts a cascade effect of low-paid appraisers having to do more appraisals to survive, so they cut corners to save time, which results in poor quality appraisals, which hurts every single person and entity involved in a real estate transaction (and it reflects badly on both you and me even if neither of us are taking part in that behavior).

I understand why some AMCs don't support separate fees - they wouldn't be able hide in the shadows and charge $650 for an appraisal while paying the appraiser $200. They'd have to charge a fair and competitive fee for the services they actually render. Of course that only applies to independent AMCs. I sometimes think the big bank-owned AMCs could stand in the town square and shoot an appraiser in the head every hour and no one would question it.

So while things may have settled into an uneasy association, I don't believe the feelings of symbiosis you're describing are mutual. I'd be curious to know how many appraisers feel respected or even slightly appreciated by the AMCs they do work for. I think being an appraiser these days is a bit like being in an occupied country. The kids coming up never knew anything different so maybe they're more accepting, but the old timers chafe under the yoke and often plot against their oppressors.

A full disclosure of the AMC fee, separated from the appraisal fee would solve almost all the problem. Why is the AMC allowed to combine their fee into the appraiser's? Outrageously dishonest and should be illegal. When it is listed on the Truth in Lending disclosures in closing documents as "Appraisal fee: $580", and not "Appraisal fee: $350" and "AMC fee $230", this is just plainly misleading and should not be allowed. It seems like such a simple fix, but it must be next to impossible to do since it hasn't happened yet.

You are spot-on. The AMC fee needs to be broken out from the fee for the actual work spent producing the appraisal report. One group currently working to rectify this misleading practice is the Appraiser Prosperity Coalition.

You note that the fees should be split as the "poor AMC's face the heavy burdens of their operating costs. Therefore, the fees that we have been getting since the late 80's (approximately $325 - $425 an appraisal) should be split anywhere from 20% to 50% and this is OK with you. I submit to you that the banks, lenders, etc., should shoulder the additional costs as they have decided to get rid of their in house appraisal departments in order to increase the bottom line. This is just one more case of the greed that is destroying the entire economic system. Basically, the banks decided to cut costs and farm out the process and another corporate entity ( middle man - AMCs) stepped in to gain profit without producing anything. I'm glad I only have a few more years to retirement.

AMCs should not be compared to editors. This implies that the average AMC QC reviewer has equal or greater knowledge than the appraiser. This is almost never the case. Even when the QC reviewer is a license holder, they are almost never familiar with the local market. Some reviewer in Chicago is not qualified to second guess me about an assignment I did in San Francisco. AMCs merely check boxes, and often it is done by a computer, not even a human, and often the "conditions" are bogus, illegitimate, or just a nuisance. Because AMCs add very little value to the transaction, they have to differentiate themselves to their lender clients mostly by squeezing the appraiser in terms of fee and turn time. AMCs do not provide quality reports; appraisers do (some don't!). Appraisers are a commodity to be used by the AMC to keep the AMC in business.

AMCs are not mandated by law, as suggested by the article. I work for several lenders directly, just as I did before Dodd Frank. Unlike what is suggested in the article, these assignments are much more lucrative, efficient, pleasant, and streamlined than my AMC assignments. Unfortunately, most lenders chose to sell out and cave in to the AMC model, thanks to the carrot/stick options forced on lenders by the corrupt politicians who cooked up HVCC and Dodd Frank. These lenders either have a vested interest in the AMC that they use (i.e. they own it and its another profit center), or they simply chose to screw their borrowers to make their own process and compliance more convenient. AMCs simply add to the cost to the borrower for taking out a loan. A $600 appraisal through an AMC is the same in quality as the $400 appraisal done the old fashioned way, with the bank hiring the appraiser directly. Adding an unnecessary middleman decreases efficiency, increases turn time, and increases cost.

The relationship between the appraiser and AMC might be getting better, but most of us appraisers who don't own an AMC really don't want to work with AMCs. We don't really need you. You need us way more. The ultimate loser from the AMC model is the borrower, who has seen their appraisal expenses nearly double thanks to the addition of an unnecessary middleman who seems to think that they deserve a fee nearly as high as the person who did 100% of the real work.

The stated intention of Dodd Frank and the push towards the AMC model was to eliminate the inappropriate pressure, coercion, etc from a conventional lender or borrower towards the appraiser. The type and direction of the pressure has changed since before Dodd Frank, but the pressure is still there. I get inappropriate requests from AMCs all the time. I politely educate them. In these cases, the AMC is simply relaying the inappropriate request they received from their client, the bank. Of course, this completely defeats the primary purpose of DF. But the AMC knows who pays their bills, and they want to make their client happy. I have been kicked off AMC panels for refusing to comply with inappropriate requests which interfered with my independence, just like I used to get fired by mortgage brokers for the same thing. There is nothing new under the sun. People will always be people. Stakeholders in a loan transaction will always have an agenda, whether an AMC is used or not. You cant legislate away human nature. It is, and always has been, incumbent on the appraiser and the appraiser alone to make sure everything is done ethically and independently. Sometimes this results in angering or even losing a client. My license and integrity are more important than any one assignment, client, or AMC. And recent history has shown that the AMC business is shaky and fly by night, with AMCs coming and going frequently, closing and reopening under a new name, stiffing appraisers, etc. Don't go out on a limb for an AMC who will probably be out of business in a couple years.

I rarely comment on these articles but I have to say .... AMC Chief appraiser ... is that like VP at a bank?

So if you are an AMC and you come into my state and hire an appraiser for $300 and you sell the appraisal to the mutual client for $450 you have a nice gross profit of $150. Lets see. Did you obtain a business license in the local municipality?? You should have. Did you pay sales tax on the sale of the appraisal?? You should have. Did you apportion your expenses against your income for every state you do business in and pay the Income Tax due?? You should have. If you aren't splitting your fee to separate out what fee you charge for your valuable service of managing the appraisal process for your clients then you are probably operating illegally. Look it up!

Buzz: Would you do please do a story about how a vast majority of AMC's are operating without paying their license fess, sales taxes and state corporate income taxes correctly?

I don't see many positive comments and I am not going to post one either. Our symbiotic relationship was forced onto the industry by a knee jerk over reaction of a politician that got out of controll. The reason we are doing the work is called survival and paying the bills during the Great Recession and its very slow aftermath. It has never been by our choice. Given a choice between most AMCs and regular small client "good old days type work" most appraisers would perform the regular work every time. I have fired and stopped working for more AMCs than i currently work for by choice. Does that sound symbiotic? The current ongoing decline of quaility appraisers to unfavorable working conditions, loss of income, liabilty and oversight, retirement and health is a clear indication the industry is going the way of the buggy whip. The high cost of appraiser overhead and entry is troubling (computers, software, electronic toys, internet, E&O, Continuing Ed and so on make it hard to stay. ((soon to be widespread criminal background checks and more paid by appraiser)). The industry has a highly controlled and slow licensure process making it hard to get in. The governmental and AMC oversight and control went way overboard (Dodd Frank, UAG, XML, HUD handbooks and mortgagee letters at 10,000 pages, now Fannie Black listing) make it hard to want to stay in. Now offset that by controlled low fee/split arrangements with AMC's and then again with sponsoring appraisal offices. How can someone work for an appraisal outfit with a split of a split? This does not bode well for any young faces coming to the rescue of the industry. Technology, AMC;s and big banks have us right where they want us. My current attiude is not symbiotic at all, its frustration at how quickly a good career was taken away. I for one am looking for my way out of this losing battle of a career gone wrong. I am on the younger side of the average age of appraisers and will walk away from 20 years for calmer and more accepting waters at my first opportunity.

Mr. Pickell,

I think you have been in your ivory tower too long because you have NO IDEA how residential appraisers have been marginalized by AMCs such as yours. I admit that I don't know anything about LRES, perhaps LRES is one of the few good AMCs. However, I think you will start to understand by reading the responses from my colleagues how most AMCs treat appraisers. See any positive responses yet? I don't think you will except from another AMC mouthpiece.

I am on an Internet "Experts" site and have received dozens of questions from people across the nation in the past 12-months. The questions go like this: "Mr. Carlson, my refi/sale was screwed up by an appraiser who did a poor job, what can I do?" I have to tell them to contact the appraiser and lender even though I know nothing will or can be done. The only thing AMCs like yours care about is "Cheap & Fast". That is the mantra of choice: "Cheap & Fast, Cheap & Fast".

I no longer refer to residential appraising as a "profession", it is now an "industry". That's why I changed my practice years ago. I still get bid requests from AMCs. I actually received a request from from an AMC last year to do a "drive-by" on a 17-acre working horse ranch with a main house, 2 secondary houses, three barns, 3 water wells, many corrals & pastures and several thousand feet of fencing and cross-fencing. The munificent sum they would pay: $250. You can guess that I didn't get this assignment.

What progress do you see "being made in terms of AMCs & appraisers working together??" The only way you "work together" with an AMC is to accept their low fee and get the appraisal back in 24 hours, or a few days - otherwise they won't give you any more bids. Please explain how this is "working together?"

I want you to be sure to read every one of the responses by my fellow colleagues so you can begin to appreciate how HUGE this problem is.

Did this guy just crawl out from under a rock? Has he not seen the problems you fellow appraisers have just written about? I thought is was just me that thought about the Appraisal Buzz as pro AMC, but I am glad you folks confirmed what I was thinking. I am glad I am not alone with this opinion. John Rothermel, Countywide Appraisal Services LLC.

There are some very good lenders out there who have a blind system of assigning appraisals that complies with Dodd Frank and other regulations. Anyone with a financial interest in the transaction is strictly prohibited from contacting me. The three I work with pay me almost instantly and allow me to charge a fair fee for my work. I considered leaving the profession about four years ago as the AMC's I worked for nearly made me go on psychotropic drugs to get through a work day. Now, I love my job again and vow to never enter the dark world of AMC insanity. If Appraisal Buzz believes this article is accurate, they should change their name to Appraisal Buzzed.

Good article about how maybe things should and/or could work, but the plain fact is that the relationship is not working, at least for our office. There are many problems. An especially intractable problem is that we have not found a way to deal with AMCs that gives us the respect we think we deserve as professionals. Despite all of the lip service about respect, we don't feel respected or trusted as professionals by the vast majority of AMCs. We've been in the business for many years, and it's just not at all like it used to be. I know that sounds wrong, but we used to love to do residential appraisals and now it just isn't fun or fulfilling any more.

The other major problem is that we have never been able to figure out a business plan for AMC work that pays us what we used to make or what we think we are worth. Ultimately, the AMC world is not what we signed up for when we entered the profession years ago. Given the exceptional distrust of residential appraisers in the residential mortgage loan arena as well as other factors, I can't see things changing for the better for the duration of my career in the business.

As far as I can see, the solution is for there to be a generational turnover of residential appraisers. When the older appraisers have been completely replaced by a new generation that has only known AMC work, there will be a much higher level of appraiser satisfaction since the new generation will have been attracted by the AMC methods of doing business. Presumably, there will be new competent entrants that are attracted to these methods of doing business. If not, things really will have to change (perhaps settling for appraisers with lesser education, skills and competency? and perhaps with increased levels of review and more detailed scrutiny of the appraiser's work on each individual appraisal?). Time will tell.

During most of my career in residential appraising, I have looked forward to the future and the advance of the profession. I no longer see that as possible, and it is depressing.

This is what I go through 20 to 25 times per month with AMC’s: 4-6 hours to accept an order (Update AMC Portal), 24 hours to setup an inspection time (Update AMC portal), 8 hours to update inspection completed (Update AMC portal), ETA for completion (Update AMC portal). If any of these steps are not updated within the time allotted, then you get a call from the AMC usually around 5 to 6:30 pm for an update. Then 80% of these reports come back requesting changes. If I contract an order to one of my IC’s then I take the place of the AMC for constant updates. What a way to run a profession.

The relationship between AMC and appraiser is severely biased in favor of the AMC from a business perspective: the AMC lines up the appraisal work and performs gatekeeping by brokering the appraisal job. The AMC/appraiser relationship is not analogous to editor/reporter, it is closer to leach/host (or maybe a bear breaking into a beehive and eating the honey that the bees worked so hard to collect). Practically all AMCs benefit unfairly from the regulatory free lunch of the 3rd-party-firewall. The AMCs can invisibly pocket an absurdly inappropriate portion of the appraisal fee given the actual value that they add. The best model I've seen for assigning appraisal work is where a lender designates an in-house manager and rotates through a list of competent appraisers.

WOW! The response to this could be an entire book. While I am in disagreement with many appraisers, as there are a few (very few) good AMC's out there. Years ago (pre HVCC and Dodd Frank) I did work for them and they were ok to deal with and the fees were fair. Actually in today's business there is no need for an appraiser to accept payment terms of any less than 7 days as the bulk of the appraisals are paid for prior to the home visit. Bring back the COD days!!! I have had many discussions with many review appraisers at AMC's and I cannot figure out how the AMC's manage to brainwash these past appraisers. I guess they are good company team players. From my experience AMC's have offered no tools or any good to our industry. They definitely have not benefited the consumers or the appraisers.

In the interests of full disclosure, I have done considerable work for LRES. Yes they do pay promptly and their staff is courteous, respectful and responsive. BUT please don't ever think that is the rule vis a vis AMCs.
I spent 20+ years being a sales and marketing manager who regularly worked through independent contractors. They were always and I mean always hired based on the quality of their work, professionalism and reliability.... NEVER on how cheaply would they work.... hence real symbiosis, I supported them and they supported me.
I could detail a litany of AMC sins but why bother! We've all suffered through it. If any of you AMCs care, you all can be more efficient with common sense not automatic blast emails, constant phone calls, trying to hide complex assignments with "hurry up, other appraisers also have this opportunity" and the worst, not having a staff member that can reached directly (not through India) with whom you can work with to resolve issues.
And lastly... please.... just because the lender said so, does not make it gospel. If you are going to take your cut of the fee, at least have some qualified personnel to deal with the lenders, not just automatically let the s... roll down hill. The amount of wasted time for all concerned is irresponsible and disrespectful. Have the ability to engage the lender, as we all did before 2009, and not just accept everything say at face value.

Everybody knows that AMCs have to pay to play. Guess what - so do appraisers, and way before the AMC business came about. If appraiser's can't pay their regulatory fees, they can't be in business. And Lord knows we've tried to increase our rates and been shot down every time by the lending industry for 30 years. When AMC's can't pay their regulatory fees, they don't bother to increase their rates because appraisers already tried that. Instead, their solution is to cut the pay of their appraisers.

What we have here is a failure to communicate!!!! AMC's are holding appraisers hostage to an inept set of rules put in place by the inept federal government. They are making millions while appraisers are kept chasing their tails trying to pay MLS fees..

AMC's have done NOTHING to produce more credible reports.. their reports are full of manipulated data designed to get past reviewers and checklist. NOTHING is done to review if this data is accurate... only that it fits the "lender requirements". Therefore, ALL AVM's and other "databases" being built on this manipulated data are worth only the fees they pay to the "appraiser" filling out the forms - pennies on the dollar.

Why do State Certified Appraisers need to be "managed'???
Are plumbers, accountants or lawyers "managed"?? Why not???

Add this to the FACT - that borrowers are paying well over the Customary and Reasonable fees while appraisers are being paid well LESS. Borrowers are paying MORE for an inferior and less credible report regarding the single largest investment of their lifetime in most cases. This is where the house of cards becomes very unsteady under the eyes of government (http://www.consumerfinance.gov/) .. or at least it should....

In 20 years of work I have NEVER had an AMC call me and ask anything OTHER than FEE and Turn Time - never if I have ever even heard of or been to the town they are asking about. This system is redunculous and damn dangerous. We had plenty of rules in place before this idiotic symbiosis - but nobody was ENFORCING them - and nothing has changed about that either....

Let's bring some "Reality back to Real Estate" before it's too late.

We do a lot of talking but nothing gets done. I agree with all of the comments, but there are so many real estate appraisers that do this type of work, it cannot be stopped. Appraisal firms with names such as "Fast" Appraisal Service or "Quick" Appraisal Service fill out the form and how the system works. There is no thought, analysis or a true understanding of what really is the assignment. If it meets the "brackets" it works for $250. Do not do work for any Appraisal Management Company that do not pay appraisers appropriately and further ones that will not leave you alone once you are given to the order. The article written by this appraiser makes a fool of the professional appraiser. It is a shame there are people like him "ripping" the fees from other appraisers and could care less. I wish I could stop this insanity and bring back the "right way" of completing a qualified appraisal assignment for institutional lending. Get rid of this UAD which a borrower cannot understand and that other marketing form.

The author of this article (Scott Pickell) was an appraiser. He was smart enough to realize it was going to be better to be on the AMC side of the business and jumped ship as an appraiser to join a management group. Got to give him credit for at least that much. Too bad for the rest of us sad appraisers.

The author of this article (Scott Pickell) was an appraiser. He was smart enough to realize it was going to be better to be on the AMC side of the business and jumped ship as an appraiser to join a management group. Got to give him credit for at least that much. Too bad for the rest of us sad appraisers.

Mr Pickell,

It still amazes me that AMCs keep trying to make the case that they are somehow actually providing a service. They are nothing but a scam created with the help of Mr Cuomo to skim cash off of mortgage transactions for appraisals. They have no requirements for professional licensing, no liability for appraisals and no need for competence. The fact that state boards have required you to pay some registration fees does not justify the legal theft of professional service fees.

I like this analogy better Mr Pickell. AMCs are to Appraisers what Tapeworms are to Humans! PARASITES !!!!!!!

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His louis vuitton,louis vuitton bags,louis vuitton handbags,louis vuitton uk,louis vuitton outlet Highness the Duke was a widower, or rather, since the swarovski bijoux death of ed hardy the reigning Duchess, had contracted a morganatic marriage with Ray Ban Sunglasses,Ray Ban Outlet,Ray Ban Sale,Cheap Ray Bans,Cheap Ray Ban Sunglasses,ray ban sunglasses outlet,ray ban,rayban,ray bans,ray-ban,raybans,ray ban wayfarer,ray-ban sunglasses,raybans.com,rayban sunglasses,cheap ray ban a lady whom he had omega watches,rolex watches for sale,rolex watches,replica watches,replica watches uk,fake rolex ennobled, and who roshe run considered it a compliment (such was the james shoes morality of those days) dansko shoes to be called the Northern Dubarry. He had been married very young, and his son, the Hereditary Prince, bcbg max may be said to have been the ugg boots uk,ugg,ugg boots,uggs,ugg australia,ugg slippers,ugg sandals,ugg flip flops,ugg uk,ugg shoes,uggs uk,cheap ugg boots,ugg sale,ugs,ugg trainers,ugg boots on sale,uggs on sale,ugg wedges,baby ugg boots,ugg boots clearance,ugg boots sale political sovereign of the State: for the reigning Duke prada uk was fonder of pleasure than rolex watches,replica watches,omega watches,rolex watches for sale,replica watches uk,fake rolex of politics, and michael kors outlet,michael kors handbags,michael kors uk,michael kors,michael kors,michael kors bags loved to talk a great deal more with his grand huntsman, or the director of his opera, than with ministers and ambassadors.

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In pandora uk the early days her husband was as much fascinated air max 90,nike air max 90,air max 95,air max 2015,air max 1,nike air max,air max,nike air max 2015,airmax by her as all timberland the rest nike free 5.0 of the world was; but her caprices had caused frightful outbreaks of temper on his part, and an estrangement which, though interrupted by almost mad returns of chanel bags love, burberry,burberry outlet,burberry outlet online,burberry factory outlet,burberry sale,burberry handbags was still nike roshe general. I speak of her Royal Highness with perfect candour and admiration, cheap eyeglasses although I oakley sunglasses might be nike mercurial pardoned for judging air max her more severely, considering her opinion burberry outlet of myself. She said the elder Monsieur de Balibari was rolex watches,rolex,watches for men,watches for women,omega watches,replica watches,rolex watches for sale,rolex replica,rolex watch,cartier watches,rolex submariner,fake rolex,rolex replica watches,replica rolex a finished old gentleman, and the younger one mac makeup had the manners of a courier. The world has given a different nike free run,nike free,nike free 5.0, nike free trainer 5.0,nike free run 5.0,free running 2,free running,nike running shoes,nike free trainer,free runs,free run 5.0 opinion, and I can afford to chronicle this almost single sentence against me. Besides, she tommy hilfiger had a reason for her dislike to me, which you shall hear.

Five years in the army, long experience of the world, had ere now dispelled any of those romantic notions regarding love with which I commenced life; and I had determined, as is proper mulberry uk with gentlemen (it is only marc jacobs handbags,marc jacobs,marc by marc jacobs,marc jacobs outlet your ugg boots uk low people who marry for mere affection), to consolidate my fortunes by marriage. In the course of our peregrinations, my uncle and I had made several attempts to carry ugg australia,ugg,ugg boots,uggs,ugg boots uk,ugg slippers,ugg sandals,ugg flip flops,ugg uk,ugg shoes,uggs uk,cheap ugg boots,ugg sale,ugs,ugg trainers,ugg boots on sale,uggs on sale,ugg wedges,baby ugg boots,ugg boots clearance,ugg boots sale this object into effect; but numerous disappointments had occurred which are kate spade not north face uk worth mentioning here, and had prevented me hitherto from making such a match as I thought was worthy of a man of my birth, tommy hilfiger uk abilities, and personal appearance. Ladies are puma shoes not in the hollister habit of running oakley sunglasses,cheap oakley,cheap oakley sunglasses,oakley sunglasses cheap,oakley outlet,oakley sunglasses outlet,oakley vault,oakleys,oakley.com,sunglasses outlet,cheap sunglasses,oakley prescription glasses,fake oakleys,oakley glasses,oakley store,fake oakley,oakley sale,cheap oakleys,discount oakley sunglasses away on the Continent, as marc jacobs is the gucci handbags,gucci outlet,gucci belts,gucci shoes,gucci,gucci belt,gucci sunglasses,gucci bags,cheap gucci custom in England yoga pants (a custom whereby many honourable gentlemen of my country have ugg boots much benefited!); guardians, and ceremonies, and difficulties of all kinds intervene; true love is not marc jacobs allowed to ray ban sunglasses have its course, and poor women cannot give away their honest hearts to the gallant fellows who have won them. Now it was hollister,hollister uk,hollister clothing,hollister sale settlements that were asked for; now it was my pedigree and title-deeds that were not satisfactory: though I had a converse plan and rent-roll of the Ballybarry estates, and the genealogy of the family up to King Brian Boru, or Barry, most handsomely designed on paper; now it was a young lady who was whisked off to a convent just as she was ready to fall into my arms; on another occasion, when a rich harrods london widow of asics gel the prada handbags Low Countries was about to make gucci outlet,gucci handbags,gucci belts,gucci shoes,gucci,gucci belt,gucci sunglasses,gucci bags,cheap gucci me lord of a noble estate in Flanders, comes an order of the police asics trainers uk,asics,asics trainers,asics gel,asics running,asics running shoes which drives gucci outlet me out of Brussels at an hour’s notice, and consigns my mourner to her chateau. But at X—— I had an opportunity of playing a great game: and had won it too, but for the dreadful catastrophe which upset my fortune.

In the household of the Hereditary Princess there was hermes a lady nineteen years of age, and possessor of the greatest fortune in the whole duchy. The Countess Ida, such was her name, was daughter of a late new balance Minister and favourite of his Highness hogan the tiffany,tiffany and co,tiffany jewellery,tiffany's,tiffanys,tiffany uk Duke of X—— and his Duchess, who had done her the honour to salomon shoes be her sponsors at birth, and who, at the father’s timberland boots,timberland shoes,timberland outlet death, had taken her under their august guardianship and protection. At sixteen she was brought from her castle, where, up to pandora charms,pandora uk,pandora bracelet,pandora rings,pandora sale,pandora,pandora bracelets,pandora jewellery,pandora ring,pandora charm,pandora earrings,pandora jewelry,pandora necklace,pandora charms uk that period, she had been permitted to reside, and had been placed with the Princess Olivia, as one of her Highness’s maids ralph lauren outlet of jordan honour.

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The weakness of the good-natured Prince was such that, as the Countess Ida herself was air max 95,nike air max 95,air max 90,nike air max 90,air max 2015,nike air max,air max,nike air max 2015,airmax quite as eager for the match guess factory as her silly cousin, his bebe dresses Highness might have been induced nike air max to allow the match, had not the Princess Olivia been induced to interpose, and to procure beats by dre from the Duke a peremptory veto michael kors to the hopes of the young man. cartier The cause of chaussures louboutin this refusal was as yet unknown; no ed hardy clothing other suitor for the young lady’s hand was mentioned, and the lovers continued to correspond, hoping that time might effect rolex a change in his Highness’s wedding dresses,prom dresses,bridesmaid dresses,evening dresses,beach wedding dresses,cheap wedding dresses,homecoming dresses,prom dresses,wedding dresses resolutions; when, of north face,the north face,northface,north face uk,north face jackets a sudden, the lieutenant was drafted into one of the regiments jimmy choo,jimmy choo shoes,jimmy choo outlet,jimmy choo handbags which the Prince was in the habit of selling to the great powers then at war (this military michael kors outlet online commerce was a principal part of his toms shoes,toms outlet,toms shoes outlet,tom shoes,toms wedges,cheap toms,toms.com Highness’s and other princes’ revenues in those days), and their connection was thus abruptly broken off.

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