Denis-"The AMC fee can be part of the zero-tolerance bucket. The AMC can bid their service based on the type of work their client requires; their client can shop their services against other AMCs to get their best price. By removing the appraisal fee from the zero-tolerance requirement, there will be no more necessity for the AMC to try to squeeze their fee out of whatever contract fee is set. They get paid for what they do, we get paid for what we do, and the two fees are independent of one another."
Releasing the appraisal fee from the zero tolerance of TRID will not solve the problem of the pushing down of amount paid to appraiser by the AMC. TRID was not in effect till recently, and for years prior AMC's were keeping a large portion of the borrower fee as tehir profit, so I fail to see where releasing appraisal fees from the zero tolerance would change that. ( though I would like to see appraisal fees released from zero tolerance )
Of course lenders dropping use of the AMC is and ordering direct is one solution, and one we do see more of lately. But cost plus, would at least make it transparent,t , upfront, as to what $ of the consumer paid goes to the appraiser (and can still be compliant with TRID zero tolerance considered as one charge total)
The excuse that it would be to difficult to accomplish with TRID because AMC;s are paying appraisers many different fee amounts, ( they pay each appraiser "their " fee ) is hogwash. The regulation is not that an appraiser must be paid "Their " fee, the regulation is to pay C and R.
Lender tells AMC we charge consumers $500 in the area, the breakout is $350 to appraiser, since we pay you $150 under cost plus. Then appraisers can agree to work for $350, or not accept the work . It is legal, is done now, can comply with TRID.
If not enough appraisers sign on to do appraisals at $350 to get orders fulfilled-, lenders are not stupid- they can cut out the AMC at that point, or reduce the amount paid to the AMC to $100, and pay the appraiser $400 ( which is exactly what the AMCs are afraid of)