Zoe
Elite Member
- Joined
- Sep 15, 2020
- Professional Status
- Certified General Appraiser
- State
- Tennessee
You are losing it. Govt helps farmers. You worked for government as law enforcement.Self-employed appraisers are not locked into any single source of engagement or employment. No different than a farmer who sells their output in the market, whether hand-to-hand at a farmer's market or in lots or batches or its entirety to a wholesaler or brokerage. No different than a parts manufacturer who's output is being sold to a car manufacturer for use in their operations. No different than an accountant or atty who sells their output in the market.
Not to belabor the point, but the consumers in every one of these mortgage-related transactions are the lenders, not the borrowers. And the govt has already brought those lenders under regulation by first imposing our services on them and then imposing further limits on the form and the sourcing of these appraisals. Govt has prohibited two of the potential sources (borrower controlled or broker controlled) of these appraisals but has left direct engagement and AMC engagement in lieu of direct engagement. This entire end of the profession already exists as an unfunded tax on commerce. Insofar as mortgage lending end of the business, most of it wouldn't even exist if the govt hadn't imposed our services on these lenders - against their will.
Moreover, when the only solution to the self-employed appraiser's problem is govt intervention into the marketplace to FORCE the consumer (the lender) to pay more than they would otherwise pay in those transactions, that's the opposite of capitalism.
In any case and as it relates to self-employed entrepreneurs, free to profit on their own also means free to fail on their own. Any self-employed appraiser who doesn't want to go commando can go seek a 9-5, where they really WILL be working for a single employer and a single source of income.
Borrowers not involved?
Mortgage fraud is still rampant.
Yes, separation of fees was not allowed at last minute on truth in lending disclosures to borrowers.
I would not bet my life Chopra (CFPB) don't get on the regulators to separate AMC/APPRAISER fees.
Chopra has authority over every lending regulator.