PAREA program

[John Hassler]

Let's see; File a complaint against an AMC. That complaint lands in the hands of the AMC rep sitting on the appraisal board.

If people can't see the problem here they are truly blind.

That can’t happen in CA as there is no board it’s a bureau and all staff are state employees. I personally oversaw many complaints against AMCs and took action many times.

 

[George Hatch]

The difference was that appraisers were not secretly defrauding mortgage lending consumers and pocketing half their fees in secret, then farming out the work to whomever would quote the lowest fee. That's totally different than soliciting for new clients. Appraisers are offering a service, we're not soliciting for a discount vendor.

Why are you purposefully distorting the issues at hand? Still having a hard time grasping the truth or perhaps switched to some whatever defense of the AMC industry possible mode?

I don't think I'm distorting anything.

I've lost count of how many times I have commented that the only fix to how the lenders do business is via govt imposing further prohibitions on them. Absent that all ANY of the participants in the market for appraisal services can do for themselves is to figure out which moral compromises to their own values that they're going to make today. Applies equally to the appraisers who are competing with each other, to the AMCs which are competing with each other, and to the lenders who are calling the shots and which are also competing with each other.

We live in the environment which currently exists. We do not live in an environment that has never existed before, doesn't exist now and will probably never exist. We can call them EVIL all we want but that isn't going to make our situation any better. Tomorrow is Friday. Friday occurs every week whether we think it should or not.

 

[George Hatch]

Let's see; File a complaint against an AMC. That complaint lands in the hands of the AMC rep sitting on the appraisal board.

If people can't see the problem here they are truly blind.

Exactly what problem is that? Because the AMCs are also regulated by those boards. Only appraisers would believe it is morally justified or intellectually consistent to exclude at least a token level of AMC representation on a state board that regulates AMC conduct as well as the conduct of the appraisers.

Have you ever worked as part of a group? If so, have you ever been outvoted by the other members of the group? I have, and I can assure you that just being present isn't enough to dominate the outcomes.

"A camel is a horse designed by committee". ​

 

[DWiley]

I have a question regarding those states with mandatory fee disclosures. Suppose the order goes to XYZ Appraisal firm, for a fee of $600. XYZ assigns to staff appraiser Pat, who has a 60% fee split compensation. What is Pat required to disclose in the report? $600 or $360?

 

[Sadie]

I have a question regarding those states with mandatory fee disclosures. Suppose the order goes to XYZ Appraisal firm, for a fee of $600. XYZ assigns to staff appraiser Pat, who has a 60% fee split compensation. What is Pat required to disclose in the report? $600 or $360?

The fee to the appraisal firm is not the same as the fee to an AMC. It might sound like splitting hairs but there is a difference between your scenario and the AMC model.

 

[DWiley]

The fee to the appraisal firm is not the same as the fee to an AMC. It might sound like splitting hairs but there is a difference between your scenario and the AMC model.

Thanks for the reply. I never worked in a mandatory fee disclosure state, and didn't know exactly how the disclosure regs work. You seem to be indicating that a split-fee appraiser discloses the fee to the firm, not the fee to the appraiser.

When you say there is a difference, are you speaking legislatively (the law distinguishes AMCs from firms that fee split), or philosophically (you perceive a difference)?

If the concern is that the consumer is unaware that Pat did the work but did not personally get all the $600 that the consumer paid, then should the fee not also be broken down by firm vs appraiser?

 

[Zoe]

Thanks for the reply. I never worked in a mandatory fee disclosure state, and didn't know exactly how the disclosure regs work. You seem to be indicating that a split-fee appraiser discloses the fee to the firm, not the fee to the appraiser.

When you say there is a difference, are you speaking legislatively (the law distinguishes AMCs from firms that fee split), or philosophically (you perceive a difference)?

If the concern is that the consumer is unaware that Pat did the work but did not personally get all the $600 that the consumer paid, then should the fee not also be broken down by firm vs appraiser?

There is a difference. The contractor with the firm knows their split. The borrower does not know the split on truth in lending disclosures. Remember ? Congress got that changed because it would be too confusing to separate fees on truth in lending disclosures between AMC and APPRAISAL.

I know you remember Sir.

 

[Zoe]

Not necessarily a contractor with the firm either. Could be employee. I'll keep going. AMC should be employee of bank and fees should be split between AMC and APPRAISAL on truth in lending disclosures.

 

[Non Sequitur]

Thanks for the reply. I never worked in a mandatory fee disclosure state, and didn't know exactly how the disclosure regs work. You seem to be indicating that a split-fee appraiser discloses the fee to the firm, not the fee to the appraiser.

When you say there is a difference, are you speaking legislatively (the law distinguishes AMCs from firms that fee split), or philosophically (you perceive a difference)?

If the concern is that the consumer is unaware that Pat did the work but did not personally get all the $600 that the consumer paid, then should the fee not also be broken down by firm vs appraiser?

I haven't given it much thought because it doesn't apply to me, but I have seen reports written by staff who work for the "We feed family first" AMC. The fee disclosed in those reports was the split paid to the staff appraiser, and it's in the low 2's. Right or wrong per La. disclosure law, I dunno'.

 

[George Hatch]

In my state, fee shops with more than a certain number of licensees are classified as AMCs and are subject to the same regs. Most the big commercial appraisal operations register under the Calif. BREAs jurisdiction as AMCs even though they might not be operating on the SFR side of the mortgage business.







The state regs don't make a legal distinction between the two labels. At most, treating small fee shops differently than AMCs could be considered a concession or exemption to the default.