On Point #3, I am again a bit divided. DW stated he did not think a cost plus would solve anything (no matter what heck he was really talking about). He may be right. If you were an AMC and you had to work within the cost plus model, how would you make yourself more valuable to a lender? Well, one way would be to continue to shop for low fee appraisers, which would likely attract more lenders, which could result in the AMC being able to charge more per "plus". At least I would do that if I was an AMC. However you might also be right, once the bank sees an operating statement that has a line item for management expense, there will no doubt be some consulting accountant looking at it and asking if the cost can be reduced. Even if futile now that we are where we are, I still support cost-plus. It would at least provide transparency to the consumer about where their additional loan fees are actually going. And if transparency is going to be the only benefit, then why not just require all appraisals include the invoice with the report? That one little tidbit is sooooo telling to the way things actually are.
Switching to cost plus would be THEIR ( the AMC ) problem. AMC's are terrified of cost plus because it has the potential to hurt them far more than it would hurt the appraiser. A number of lenders would drop the AMC model and direct order instead. Any increased direct lender order volume will help appraisers say "NO" to basement fees.
Your point that an AMC could create value by offering a lender lower fee appraisals- its possible but would be harder for AMC's to do, because , Any increased direct lender order volume will help appraisers say "NO" to basement fees.
For lenders using AMC's, they'd arrange a cost plus and decide on an acceptable appraiser fee for their borrowers in an area, end of story.
I think lenders realize offering an appraisal that is few $ less than the competition is not going to give them a significant market share advantage. But if it becomes an issue with any individual borrower, a lender can opt to reduce the appraisal fee to borrower by that $ differential and lender would pay it - well worth it for them to make the loan. ( and they can probably charge the borrower $ more in another fee or roll it into the loan and make it back ))
True transparency is not achieved by including invoice with appraisal ( after the fact), It has to be upfront, in the application phase ..and not just the $ amount and any splits explained upfront, but also explained to the borrower, if this lender uses an AMC, whether the AMC will be using a lower fee as a component of appraiser selection, and what that means as far as which appraiser might be selected. ;