Customary and Reasonable - Appraiser Kryptonite

Wednesday, May 2, 2012

I just received a copy of a letter issued by the Alabama Appraisal Board to several Appraisal Management Companies. Click here to read a redacted copy.

I’ve opined in earlier Appraisal Buzz articles that I have been quite surprised that neither an AMC or a Lender has been legally challenged on the C&R component of Dodd Frank. The regulator, as I understand it, is a State’s Attorney General until such time the Consumer Finance Protection Bureau has instituted final rules. The penalties for violating the law are $10,000 per day. Both the Lender and the AMC are liable.

Many lenders assume they can pass this risk onto their AMCs. I think the law is clear on that. Both are responsible. It is never a good plan to gamble on compliance issues. There are all sorts of risks associated with the appraisal process. This one is easy to implement; not so easy for lenders who have been enjoying the benefits of free appraisal management services. 

Bill Matchneer with Consumer Finance Protection Bureau spoke to the Collateral Risk Network in New Orleans a few weeks ago. He mentioned that there are a number of rule making efforts underway. Unfortunately the C&R issue has no impending deadline so it will be highly unlikely it will be addressed this calendar year.

Could Alabama may be the “mouse that roared”? I gave the Alabama Appraisal Board Executive Director, Lisa Brooks, and their counsel, Neva Conway a call. The letter was initiated due to all of the complaints coming from appraisers, Neva explained. At this time Alabama does not know what they will do with the responses they receive.

Contacted for a statement regarding the Alabama Board’s request for methodology used to determine customary and reasonable fees, Don Kelly, Executive Director for the Real Estate valuation Advocacy Association commented:

“While REVAA appreciates the efforts by the Alabama Board to pursue its responsibilities for AMC registration, we believe the request for AMCs to supply the Board with the methodology for determining customary and reasonable fees is beyond the Board’s statutory authority. The Dodd-Frank Act requires AMCs to pay appraisers a customary and reasonable rate and the Federal Reserve Board has issued a definitive regulation on the matter. Neither the Dodd-Frank Act, federal regulation or Alabama law authorize the Appraisal Board to seek such proprietary information.  We urge the Board to forego its request.”

I would urge that appraisers remain “noisy” on this topic. The consumers of appraisals are exclaiming very loudly that the quality of appraisal reports continues to decline. Ok folks this isn’t “rocket surgery”.  As long as we have misaligned incentives in place to engage the cheapest appraiser we wont solve the quality issue.  I listen, impatiently mind you, when Lenders and AMCs tell me that fee and quality are not correlated.  Common sense is not only uncommon it is your freaking super power. Appraisers, you really are making a difference. Many appraisers are busy, fees are going up, and the leverage on the fee issue you thought you lost is slipping away. Smart lenders and AMCs know that. Identify them, perform your due diligence, be professional, and soar.

Comments

This is the ONLY issue that matters to appraisers today.  For homeowners it should be transparency regarding the appraisal fee on the HUD-1.Anyone who can find a solution deserves a statue in their honor to be placed on Andrew Cuomo's door step.  Be a hero Joan.  Be a hero Dustin.  Forget everything else and concentrate on fighting for justice for appraisers.  Anything else you do with your life pales in comparison to solving this problem for appraisers and homeowners.

I am glad to see that someone is challenging the AMC's on the fees, it is about time and we need to continue to pursue this approach. This is similar to the immigration problem, the Fed's have a law but won't enforce it but they don't want the states(or anybody else) to enforce it. Well congress pasted a law but they haven't wrtten the regulations to implement it. If the appraisers wait for the government to solve the problem we will all be in the poor house. The real solution is for the appraisers to ban together and set a minimum fee and do not accept anything less. I feel the minimum fee for a standard SFR should be $ 500 and for 2-4 unit $ 800 and the appraisers should set the turn time based on the complexity of the assignment. If 75-80% of all appraisers would stick to this the AMC's & Lenders would have no choice but to pay the fee, they need the appraisals. We the appraisers have the "Hammer" if we would use it. Yhey can not provide the required appraisals without us.  John Pratt

I am an appraiser with 22 years experience and a degree from one of the top universities in the country. My residential reports contain a higher percentage of time consuming report specific narrative than I typically see in typical residential appraisals.  I will not work for cut rate fees and am living proof that a higher fee will get you a more thought out comprehensive report from a veteran of this industry.

Just say "Communism" or "Slavery".  They're easier to say than "customary and reasonable fees" ...Also, every time a bank charges you a fee, demand proof that it's "customary and reasonable".If lenders had ever worked a hour in their lives, maybe they'd understand something about effort expended to achieve an end.  Tell a banker you'll pay him $100 to do something whether it takes two days or two weeks and that you'll be able to ridicule, threaten, throw tantrums, withhold payment, sue and generally bother him for as many years as you see fit, then note his or her response.  That's what they're telling us to do. Oh, I wish I wuz in de lan of cotton ...

The fact that fees are increasing is a result of more demand.  To say that AMCs and lenders are responsible is laughable

From REVAA's website. MembershipREVAA members are proactive in their efforts to promote and expand the valuation industry. They produce and deliver real estate valuation and pricing products, which include Appraisals, Broker Price Opinions (BPOs), Automated Valuation Models (AVMs), and other innovative products, that benefit mortgage investors, servicers, originators, and borrowers. An organization with members that supposedly produce appraisals, is stepping in to protect the lender from providing the methodology of determining Reasonable and Customary Fees?  That appears counterproductive on the surface?   How many appraisers are actually members and how actively do they promote appraisal?  I went to REVAA's website and it appear to only follow BPO legislation as well as other sources of valuations, other than appraisal.  In fact the website directs users to an article that discusses alternatives to an appraisal.

REVAA & TAVMA are fighting anything and everything with regard to paying appraisers fair fees.  Don't let their website fool you.  REVAA has been far more vocal and involved in fighting than TAVMA recently. 

Personally I predict AMCs could have a short lived future and they're already scrambling to keep the appraisal fees in line with their profits. Now that lenders are accustomed to not having the loan officer order the appraisals and while many use AMCs there are also many banks and loan companies who continue to order their own appraisals because they've set up a separate department to handle the ordering to make them compliant. When banks and loan companies have this type set up it helps everyone involved....the bank cause they know first hand what's taking place with the appraisal...the appraiser cause they're getting their normal fees and even the customer because the additional fee for the AMC isn't being added to the loan fees. It's a win win for everyone except the AMCs. Just think...if every appraiser would not cave in to the lower fees offered by the AMCs and let them fade into the sunset that would be a lot less stress for appraisers to deal with. Keep in mind though...one of the reasons AMCs have gotten so popular is because appraisers got sloppy with their work. So in order to take our industry back from the AMCs we're going to have to do top notch reports with credible values in a timely manner and stick to our own fee schedules and not the AMCs.

is the lack of licensed/certified appraisers reviewing reports at AMC's. When you tell an appraiser to make a change to the report  that directly effects the outcome, you have performed a review. The USPAP standard the defines "Appraisal Review" is clear.  I have turned in reports that display value conclusions predicated upon the comp with the lowest Gross Adjustment (most similar) and been told "I want you to use a weighted percentage method".  This is a breech of USPAP. The AMC's are staffed with cheap, job-fair applicants using a checklist. When they are forced to hire appropriately, the reasonable and customary fee thing will take care of itself. 

I think it's a wonderful thing they are doing in Alabama and I am going to urge my board (Massachusetts Board of Real Estate Appraisers) to do the same! The only reason you would oppose this disclosure is if you were paying less than customary or reasonable fees and making significant profits off of the backs of quality appraisers! AMC's will soon be a thing of the past!  

Fees are a supply demand issue.  To "set" fees when there are more appraisers than work is just not going to work.  What one person's customary fee is will be another's low fee.  We can't force people to work for a certain fee.  Dodd Frank is "frankly" full of BS.  It is an unenforceable piece of legislation.  Fees will eventually go up as the supply of appraisers go down.  I only work part time as an appraiser since I have another job.  But I moved to an area where there are few appraisers.  I can pretty much get my fee.  And in one location I can get nearly double my fee because no one seems willing to go there.The median age of appraisers is quite high.  The increase in appraiser requirements will limit the field.  Due to the present fee structure appraisers can't afford to train people.  So in the next 5 years (maybe 10) there will be far fewer appraisers as we retire or get other employment.   I already had one AMC tell me they can't find appraisers in certain areas of the country because so many retired.  What they most likely mean, "I can't find appraisers to work for my fees." In metro areas this might take awhile longer than in rural areas.  But I can already sense a shift in how AMC's treat me as a rural appraiser.  I had one company want me to do an order at a particular fee and I just said "NO, this is my fee or forget it."  Well, they eventually submitted to my fee. So I think appraisers would do well to let the economics of the situation work.  In metro areas it probably means not training anyone.  Get the supply of appraisers down, and fees will rise.    

Very good point!  I also appraise in a rural area.  Often it takes much longer and I charge accordingly as to where I must travel as well as the difficulty in finding comps, data, etc.  Yesterday I received an order for an REO at a fee of $290 and a 2-day turn...NOT!!  Another appraiser was willing to take it ... have fun with that!  When we apply to an AMC we are asked for our fees.  Now when they call I give them a higher rate and they quote me on the fee they have in my file.  I just remind them that fees should be updated one to two times a year since now fees are beginning to return to near normal as well as gas is $1.00 more per gallon!  Some AMCs are wonderful and others not so much.  We all have the right to pick and chose who we accept assignments from.

When they are talking about "customary and reasonable fees" are they talking about giving or receiving?  If an AMC talks about their fees, they could say that they have been paying their fees for many years and therefore they would be consider "customary" and if appraisers had been accepting these fees all of these years, what's to say they aren't "reasonable"?The fact appraisers have to go through AMC's to get a majority of their work, the new appraisers that joined an AMC to get work would not consider their fees to be reasonable.

What's sad to me is that appraisers have no real advocates and the banks, lenders and AMC's are in control of everything. Common and customary fees will continue to be a dream unless we have adequate representation. Appraisers will continue to be forced to provide appraisal services for cut rate fees to feed their families and keep the doors open. Complaints about quality are not changing the ways the AMC's choose appraisers. They only change the number of forms and the amount of data we are required to provide the client to avoid paying higher fees for reliable appraisal  services.       

I think it is time to be heard. We have all worked hard to do a good job in our field. We should take appraiser opinions and ideas and see if we can combine effots & make a difference in this profession that we have chosen. Please resond if we are going to change anything Take a stand!!!!!! 

MISMO is the death to the Appraiser Profession! MISMO is a total regression method to do away with individual appraisers and make it more quickly for the GSE's to sell their paper easier to the Wall Street Boys to dump within the world global banking system. I think that they all forgot Statistics 101; correlation does not predict cause and effect. They will not learn this  untill the next mortgage finanincing crash happens.

The letter is accurate as all appraisers I think would agree.  Lowering fees means an appraiser needs to submit more reports per month in order to stay in business.I have had borrowers divulge they are paying approx. $500 for an appraisal yet, my fee is sometimes less than $300.  (of course I never discuss my fee with the borrower) Moreover, I know (from being a former staff appraiser) appraiser fees can even dip below $200 per report.Customary and Reasonable are (in my opinion) purposely vague as 'customary and reasonable' might mean what an entity has been paying a particular appraiser instead of what is 'customary and reasonable' for the profession. 

I appreciate your informing us about this letter.  Good stuff: "Proper fees allow appraisers to spend sufficient time in the analysis of the property being appraised".  Conversely, when AMCs suck up 50% of the fee for doing 10% of the work, appraisers are faced with cutting corners to make up for it.  Let's stay noisy.

It has become customary for AMCs to pay unreasonable fees to their appraisers.  The longer this goes on the more customary it becomes.  The AMCs keep more than half of the appraisal fee but do a lot less than half the work of producing the appraisal.

As long as appraisers continue to allow others to control their profession, they will continue to be treated as a rubber stamp for clients and a door mat for regulators. This has been the case for all the years I have been around. Lots of whining by appraisers - no action on their part.

For a while, fee got better.  Now they are regressing to the old "nothing"  We as Appraisers cannot sit back and expect someone else to look out for us.  We must learn how to say "NO".

We have another issue to take on...the unreasonable demands on the appraiser's time.  When AMCs demand a completed report within 24-48 hours, not to mention immediate response (within minutes) to make a decision as to whether or not to even take an assignment, and daily (or more ) "updates", it affects the appraiser's ability to make an accurate, high quality, report.  It seems the AMCs are bargaining away not only our fees, but our time.  It used to be common for a report to take 7-10 days, and we rarely ever got "call backs" or revision requests.  Now they want a report within 2-3 days, and we have more revision requests per day than we do new requests...for silly, minor things such as missing a check-mark or having a space between a comma in one spot, and not in another!

You are absolutely right, we as appraisers most learn how to say no, the AMC is neither our friend nor our enemy, they are here to make a buck, so should you. First we need to bring down our expenses to a bear minimum, so we can afford to say no. then simply name your own price, this is the minimum price we will do this for, (don’t be afraid to ask for a fee increase for each and every assignment, and don’t be afraid or reassignment) to work for less means loosing money. Be as friendly as possible, you will see they will try to accommodate you, they maybe upset in the beginning, but eventually they will understand you, you are here for the same reason they are.

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