Interview of Jeff Schurman and his AMC Full Fee Hypothesis

Friday, June 8, 2012

Recently the Appraisal Buzz had the opportunity to sit in and listen as Tony Pistilli, Chief Residential Appraiser at U.S. Bank, and Jeff Schurman, Executive Director of Leading Causes LLC, discussed Jeff's recently published article. If you haven't read it yet you can find the full version here. We highly recommend it as it a great Jeff&Tonyread with a ton of pertinent information for appraisers and AMCs. We were enthralled by the conversation and were able to put together some of the highlights for all of our buzz readers.

Tony:  Jeff, thank you for taking the time to join us and talk about your white paper "The Appraisal Management Company Full Fee Hypothesis." Your article defines the reasons why a "Full Fee" model is vital for the survival of AMC's in this age of market and financial changes. What are some of the main reasons you believe that the current appraisal and AMC models are unsustainable?

Jeff: Thanks, Tony. The mortgage finance industry has changed significantly in the last 30 years. Yet the AMC business model has remained substantially unchanged. We still follow the 3-day turnaround time convention our ancestors sold to consumer finance companies in the '80s. We still make margins by buying appraisals low and selling them at or near retail, discounting real value that both the appraiser and AMC bring to the transaction. Rick Grant and I wrote the paper to encourage AMC leaders to consider the benefits of paying appraisers their full retail fees and then charging lenders a separate fee for managing the transaction for them. Underlying our hypothesis is our belief that the full-fee or cost-plus model is necessary to ensure the future of these co-dependent industries.

Tony: Describe some of the recent changes that have precipitated this call for change.

Jeff: As recently as 5 years ago, AMCs managed between 5 and 17 percent of appraisal orders. In that time, appraisers survived and thrived despite the fact that most AMCs paid less than full fees. Revenue from AMC work, many appraisers said, was enough to pay the light bill and fill gaps in order pipelines. Appraisers relied on full-fee client business to remain profitable. The consolidation and nationalization of mortgage lending, along with centralized loan production, and the infusion of the HVCC (Home Valuation Code of Conduct) into the system fundamentally changed the appraisal acquisition model. Today, many appraisers who once managed to turn a profit with a 5:1 ratio of full-fee to discounted AMC-fee orders now contend with a 1:5 or 2:5 ratio. Meanwhile, AMC fees haven't risen to majority client levels. Appraisers are losing hope and dropping out of the profession. And prospective appraisers are finding better career prospects in fields like healthcare and IT. It's time for AMC leaders to re-imagine their industry now that they lead it.

Tony: Your paper outlines 20 benefits of the full-fee model; are there one or two benefits that stand out beyond the others?

Jeff: They all stand out, at least in our minds. We capped our discussion at 20 benefits but there are more. In fact, we've gotten emails from several industry leaders presenting additional benefits. And they're all important. However, if I had to choose just one overarching benefit I'd say it is this: Paying appraisers their full (or retail) fees removes the single-largest barrier to acceptance of AMC as legitimate business partners. Until and unless AMCs pay appraisers at or near their full-fee levels, they'll be viewed as predators rather than partners. That doesn't make for a healthy supplier/client relationship. Take that matter off the table and 95% of the contentiousness goes away.

Tony: You speak of how competition is the catalyst for many of the business practices in the appraisal industry. Do you believe that lenders place AMC's in the same competitive environment AMC's place appraisers? 

Jeff:  Yes. As much pressure as AMCs put on appraisers for fee concessions, turnaround times, and supporting documentation, mortgage lenders exert the same pressure on AMCs. Lenders seek certainty about what they're going to pay for appraisals, especially now with tolerances built into the Good Faith Estimate, and the specter of the Consumer Financial Protection Bureau (CFPB) looming large.  Therefore, they'll negotiate location-dependent tiered pricing and pit one AMC against the other(s) to win the best pricing package.

Tony: What would happen if the industry switched to a model where the AMC fee was paid by the lender and not the consumer? Would Lenders become more conscious of the fees? 

Jeff: Lenders scrutinize every settlement service fee looking for cost savings. Most look at the HUD-1 where they can see all the fees in a list form. They may glance at the appraisal fee on the HUD-1, and think, "Ok, that's reasonable," since most AMCs charge them a blended appraisal/AMC fee that's around the retail cost of an appraisal, and move on. I'm fairly certain though that this will change. Amid so many calls for transparency in mortgage disclosures, it seems to me CFPB will require the appraisal/AMC fee to be unbundled on the HUD. I support such a move for several reasons.

Tony: What are some of these reasons, in your view, for separating the appraisal and AMC fee?

Jeff:  Appraisal reports do not simply show up on a loan officer's desk. Someone with local knowledge of the appraiser pool in the area must shepherd the order into, through, and out of the production pipeline. Thus the loan originator has exactly two choices: They can do this work themselves, or hire an AMC to do it for them. Either way, the lender incurs a transaction cost. Separating the appraisal production cost and the AMC transaction cost benefits the lender and consumer through clarity about what comprises the total cost of the appraisal transaction. It also benefits the AMC industry by providing clients a quantifiable means with which to compare their various AMC alternatives, as we explain in Benefit #8 (in the paper). A lender considering two AMCs can use the AMC fees as a negotiation point and as a means to quantify the value packages the AMCs offer in their proposals. 

Tony: You suggest paying full fee will provide better quality appraisals; can you expand on that thought?

Jeff: The full-fee model will certainly attract a full complement of appraisers to the AMC industry. As a result, AMCs will gain leverage to demand the very best service quality. AMCs invest heavily in quality controls from end-to-end in the appraisal order, production, and delivery continuum. All this costs a lot of money, money that could be invested in paying appraisers full-fees and then demanding, not asking nicely and hoping for, appraisals to be delivered with a minimum tolerance for mistakes, post-delivery rework, addenda, re-orders, and such. It shifts the burden of accountability, and the quality investment, to where it should be… with the appraiser.

Tony: How do you rationalize the competing pressures of free market competition in negotiating fees versus what you admit in your paper could be viewed as violating the Sherman Anti-Trust Act?

Jeff:  I kept thinking that President Reagan would be terribly disappointed in us. Actually, writing the paper helped us to clarify our thoughts on the trade-off of free market fee negotiations versus price fixing to solve a lingering problem. Our hope is that AMC leaders read the paper and contemplate an industry in which appraisers, and AMCs, are seen by lenders, politicians and regulators as valued advisors rather than necessary inconveniences that don't get along.

Tony: Leading Causes LLC has been championing this type of Cost-Plus Fee payment system. What are some of the methods you have been using to get this information out and who has been helping you with your message.

Jeff: I've launched the Mortgage Third Party Risk Blog, to discuss such topics as the inevitability of AMCs, why lenders and AMCs do what they do, and offer suggestions for how to compete in this new mortgage settlement services environment. Rick's firm, RGA Public Relations, is circulating the paper through mainstream and social media channels. And, we're coming up with a banner or badge we'll award to AMCs that commit to pay full fees that they can display on their homepages. I envision a light blue banner or badge that simply says, "FAIR." We're struggling though with what the acronym will stand for. The "FA" could be "Full Appraisal" but the "IR" remains elusive.

Tony: Well Jeff I really appreciate you taking the time to go over this topic and your white paper with me. This is an extremely interesting topic that will spark a lot of conversation and perhaps a lot of change in the appraisal industry.  I applaud you for taking on this topic for the betterment of our business.

Jeff: Thank you, Tony. I hope it helps. 

Jeff Schurman, CAE, is the executive director of Leading Causes LLC, a leadership and business development advisory firm that helps mortgage lenders, third-party service providers to assess strategic, operations, reputation, reporting and compliance risks that accompany sourcing of real estate mortgage settlement services. The firm also provides administrative and copywriting services to businesses and nonprofits. Jeff is the editor of the Mortgage Third Party Risk Blog, and the former executive director of the Title Appraisal Vendor Management Association.

Tony Pistilli is the Chief Residential Appraiser at U.S. Bank in Minneapolis. His responsibilities include the development of valuation products, policies and procedures for the residential lending process. Tony has been involved in the real estate appraising and lending industries for over 25 years. Prior to joining U.S. Bank he was president of Park Appraisal Service and has worked at several mortgage companies and the Department of Housing and Urban Development.

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If Schurman is successful with his branding of particular AMCs as "Fair Players" those AMCs will immediately have a large pool of appraisers to pick from and will then have the ability to choose from that pool based on quality and customer service. With the appraiser shortage looming ahead those AMCs will be positioned to sail past their competitors, many of which will likely be casualties of war.The rest of the story is that then particular appraisers could be branded as "Blue Ribbon" appraisers. This brand would signify that they are appraisers who have the expertise, knowledge and commitment to customer service required for mortgage lending. There are many appraisal niches and branding would identify appraisers who make mortgage lending appraisals a priority in their practice. This could all lead to premium fees for premium service for some market participants thereby giving incentives for excellence.Th consumer would be well served by getting a mortgage commitment based upon a fully supported Opinion of Value by a well qualified expert, not the fastest and cheapest. If it's a purchase contingent on appraised value or even a refinance it is of critical importance. The mortgage lending appraisal brand could be more valuable than any designation given by any professional appraisal association and could ensure the maintenance of quality, and stop the use of appraisal mills, unlicensed runners, and the unacknowledged use of MLS photos, all of which many AMCs turn a blind eye to as long as they are getting "fast and cheap".-Frederick Giebel, Certified General Real Estate Appraiser-NJ

I work with an AMC that bases consideration for higher appraisal fees on an appraiser quality rating system. Initially this appears to be a reasonable system to pay more experienced appraisers a higher fee but, after making numerous trivial, inconsistent corrections; I concluded part of the motivating factor for the review process is to get the appraiser rating as low as possible to keep the fee down. Once I started asking questions about the rating system, the orders disappeared. Part of the problem with the AMC’s is constructive feedback. It seems the AMC’s would rather eliminate good appraisers than mentor them about the things they like or dislike about an individuals reports.

Based on your description of the AMC appraiser quality rating system and their nitpicking, I would guess  the ratings are not about good appraisals (ers) but about encouraging appraisers who make appraisals that are high enough to cover the loan amount and discouraging fair appraisers. The rating system is just an excuse or cover to pick certain appraisers. 

Who is rating you Mr Blue Ribbon? Kids who were hired at college job fairs. They were hired because they know how to operate a computer and because they have an unmarketable college degree. Until AMC's are forced to hire appraisers and not clerks working off a checklist, you will be beaten to a pulp. AMCs have "no skin"in the game. All they have is payroll (cheap payroll). Do what I do ....I make them have me talk to an appraiser. That is your right. Only an lic./cert. appraiser can review your work. When AMCs call you for meaningless revisions that cost you time and labor, tell them you want to speak to their appraiser.

I bet you are right. I do consistently good work and of course have many little nitpicking things to deal with. I have recently been sharing some of my work with a freind who is now on his own after working with a company that had almost all regular mortgage company clients. He is now getting on with some AMC's and having to add more to his appraisals than he ever did, not to be "UAD" compliant but rather "AMC" compliant. I had to tell show him all the little extra idiotic statements, text formatting, etc. Things like if two comps are C3 condition but one is at the bottom of that and one is at the top of that rating and you make any adjustments they AMC's will not know what to do but stip you since they don't even know what C3, C4 really means. It is simply NOT profitable. I am making my slow exit as I transistion into rentals and flips. I wouldn't take on a trainee for anything. No one would work for half of half and do a decent job anyway. "Appraisal" the way that we view it is a dying industry, just like my last career, electronic repair was. In our throw away world appraisers are the next throw away. Some guy will create or whatever using software, runners to take photos/measurements and people in India to fact check and produce a 12 hour "appraisal" for $50.

I have another 9 months and my IT certifications are complete I will finally wake up from this horrible nightmare!  An industry that has been raped and pillaged and I am not sticking around to see the new model when it finally is restructured.  To my peers good luck and you will always have my respect.

On average, I have to work 7 days a week to complete 5-6 appraisal reports. The average fee is $350-400 and involves miles of driving to take unnecessary original comp photos(50% will be mailboxes and driveways). Rarely, is a higher fee accepted.  Appraisal work simply does not generate  professional income any longer. The obese expanded reports,  useless 1004mc, free UAD data mining feature, redundant XML & PDFs. plus the idiosyncratic delievery systems employed by various AMCS are often employ very time consuming and frustrating unique log ins and  report filters. A report may have to be resent several times over tirivial points, taking hours to finally complete because one AMC wants the AMC to an N/A while another wants a zero or blank. Or another wants HUD after the lender while another wants it removed.   Yesterday, I got a request for $45 to drive by a property, take original comp and listings photos. This is the future. Appraisers will not be paid higher fees. Banks and AMC will come up with "appraiser assisted" valuation products.  The overhead and liabilty of appraisal work is equivalent or to  that of an attorney. Now, The kid that cuts my hair is making more money with very litlle overhead and no stress.A standard 1004 UAD/ MC appraisal should cost $600 minimum. Do you really think Banks and the AMCs they often own will pay that? I doubt it very much. Once we provide enough data for free via the UAD XML formats, Banks will pressure ( pay lobbyists) to do away with standard appraisals for 90% of loans, Appraises will go out of business. It is not worth a new appraiser to invest time and money getting licensed with such an uncertain outlook. Older appraisers will simply age out.  If the fees are going to go up, it better happen right away. Think of it as climate change. The appraiser ecosystem is dying. As it is ,there aren't enough appraisers left who are willing to take on the risk and expense to train replacements. 

Has become nothing but a joke ... AMC's are nothing but old mafia style protection rackets or, if you prefer, extortionist organizations based on the mafia business model. The whole system is designed to keep appraisers off balance, scared and broke.  If the banks and AMC's wanted quality appraisals, they wouldn't be paying appraisers what they were making thirty years ago.  With their Wal Mart/slaver mentality, the lenders should just send their appraisal work to China, India and Mexico.  I'm sure semi-educated, third world peasants could do a "good" virtual job and much, much cheaper.  Like I said, it's nothing but a joke, a bad joke. I hope the whole thing blows up in the faces of the lenders and AMC's.

The current AMC business model is not sustainable for most appraisers.  Three day turn times for $200 puts the appraiser and lender at tremendous risk due to mistakes and lack of analysis, and do a  great disservice to the borrowers who rely on their reports.  Few appraisers comply with the USPAP due to the time pressures involved.  I know, I review their reports frequently.Does the lending industry really want millions of dollars in collateral put at risk by an appraiser making $20,000 after expenses and taxes.  Its more common than you think. I applaud anyone in the industry that recognizes the problem and is willing to consider alternatives.  And for those AMCs and lenders that are paying higher fees and allowing longer turn times, your efforts are noted and appreciated.  The issue ultimately has to be repaired by lenders rely on appraisals. Otherwise, as seen in the other posts, there will be no appraisers.  

I've never seen a more powerful group whine as much as appraisers do. YOU ARE THE MOST POWERFUL ENTITY IN THE ENTIRE TRANSACTION !!! Just cut their values & they will get the picture! Let's see, I've got a stack of appraisal assignments paying $300 & another stack paying $450. Hmmmm. Which assignments will get full value? Can you even tie your shoelaces?

If we did that, we would end up in jail. We have to do a good job, even if we don't get paid, even if the deal doesn't go through. We get in enough trouble when the deal doesn't work legitamatly, the lender gets mad, the underwriter is mad, the loan officer is mad, the borrower is mad, and all of those people write a complaint, and then the Board of Appraisers, who is supposed to back us up, fines us for doing what we are supposed to do, providing a fair market value, independant and without pressure. I think the real solution is to let the underwriters write their own appraisals. Then, the guy approving the loan is using the banks own criteria to pull comps, and come up with a value.

Obviously, you know nothing about being a professional in the appraisal field.  If you did, you would know that as an appraiser you are held to the same standard of ethics to complete the appraisal accurately no matter what fee you agree to when you take the job.  If as an appraiser, I don't want to work for the low fee, high pressure AMC, then I don't take their work.  It is just that simple.  But if I do take the low fee order, that order gets the same time and attention AND correct value opinion as if I were getting a higher fee from a non AMC client.  Wow, you must be a loan officer or a realtor to make a comment that dumb....

Full Appraisal Income Responsibly!!! And to anonymous... It is highly unethical to accept a fee, whatever it is, and then deliberately turn in a report that is not objective and professional. Turn down the work. I have done just that and am working a second job until things change or I find a better paying job and no longer need to do appraisal work.     Fly by Light App. 

The horses have been leaving the barn, and now you want to try to close the door. Or should I say good appraisers have been leaving the appraisal industry by the thousands, and now you want to fix the problem. In my opinion it's already too late. Thousands of more appraisers will continue to leave for other careers with more livable wages, or retire early, before the lenders open their eyes, and recognize the problem. What Mr Shurman proposes makes all the sense in the world. For the past four years, appraisers have been shouting out to the deaf ears of the lenders and AMC's to address these same concerns. However, I seriously doubt that lenders and AMC's will be willing to pay higher fees, or deal with turnaround times, or scope creep. They just don't get it. After 25 years in the business, I won't be sticking around much longer. Sorry, its too little, too late.

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