AMC purpose

[chad hampton]

Don't make me send you a bill. You already owe me well into the 5 figures for all the time I spend correcting you It's exhausting work.

I'm glad Im not the one that thinks 2-party and 3-party mean the same thing. It's got to be humiliating.

 

[George Hatch]

You have no reference for lenders being prohibited from using appraisals performed by either the lender or an AMCs employees. No regulation pertaining to AMCs prohibiting them from using employees to perform appraisals. None. It is untruthful for you to say or to suggest otherwise. Especially when you know you don't have what it takes to support your allegation.

 

[chad hampton]

You just said it. You have to separate the sales side from the appraisal side. That's what the AMC is. If the AMC is now the appraiser side, there is no separation.

You know as well as I do that wasn't the intent or the wording of AMC legislation when it was written 15 years ago.

 

[Surf Cat]

That's the same way the direct engagement lenders do it

Of course..... they don't want to be left behind when they see the other side making bank.

If the GSE's and other lenders want to source out and not have appraiser staff on hand to manage....fine. But they should have to pay for it.... I mean, they're not paying staff salaries, insurance and benefits right? That has nothing to do with my fee..... which the borrowers pay anyways.

The only way the appraiser (residential) is not going to be coerced into hitting a number... is to have a three-tiered system for the borrowers.

Based on the borrowers income, creditworthiness, savings, and all the other particulars lenders look at, depending on what the "market value" for their house is, here's how much their APR, payment, and loan terms will be.

The "ultimate", ideal, loan-term shouldn't come down to the house "has to be" worth this much.

 If the market value of your home is A here's your APR and payment. If the market value of your home is B here's your APR and payment. C...same thing here's your APR and payment.....sorry, with option C, since you didn't take care of your home and it has a lot of deferred maintenance, you don't qualify for the cash out with the refi. In other words, no one's deal gets killed by the appraiser.

Hey, if you don't agree with my analysis, send me the sales that prove your case and I'll have a look at them.

This way the appraiser would be left alone to do their job. It wouldn't be all on the appraiser's shoulders to make the deal work.

 

[djd09]

That's what the AMC is. If the AMC is now the appraiser side, there is no separation.

they think the mb estimating value via a waiver is separation...

 

[George Hatch]

You just said it. You have to separate the sales side from the appraisal side. That's what the AMC is. If the AMC is now the appraiser side, there is no separation.

You know as well as I do that wasn't the intent or the wording of AMC legislation when it was written 15 years ago.

Slow down. Think it through. The prohibited conflict of interest is between sales and appraisals, not between AMCs and fee appraisers. The AMC is the appraisal side, not the sales side. It is illogical to conflate the role of the AMC with the role of loan origination.

No different than the lenders which use an in-house appraisal dept for some assignments and fee appraisers for others. That's also not a conflict between sales and appraisals.

In terms of relationships with the lender and excluding MB-select, there is no difference between a fee appraiser, a fee shop, an AMC or an in-house appraisal dept at either the AMC or the lender. None of them are engaged, controlled or paid by the loan officer or the mortgage broker.

Neither the AMCs nor the lenders were ever prohibited from running an in-house appraisal staff, and the lenders were never prohibited from using those appraisals. The "changes" to which you are referring were limited to bringing the AMCs under state regulation whereas they were previously unregulated. That is not only the original substance but also the original intent of those regs.

I do not care what happens to the AMCs. If Congress outlawed them tomorrow that would be fine with me. I wouldn't spend 2 seconds fretting their demise. If it were up to me I'd rather see the lenders go to 100% direct engagement. As long as they didn't go back to MB-select or allow the lender's loan officers or the borrowers to control the appraisals then that's what counts.

 

[Dublin ohio]

You just said it. You have to separate the sales side from the appraisal side. That's what the AMC is. If the AMC is now the appraiser side, there is no separation.

You know as well as I do that wasn't the intent or the wording of AMC legislation when it was written 15 years ago.

I didn't realize that AMCs originate loans

 

[chad hampton]

You show me where is says a 3rd party AMC can also be an appraisal company using employees as appraisers?

I've spelled out many times over the years the NC laws that state to be considered an AMC you have to operate and maintain a panel of independent fee appraisers. I'm sure that's written in most every piece of AMC legislation in every state.

You like to argue just for the sake of arguing. Just wordsmith and mental gymnastics to spin something that is fairly black and white to have it mean something it doesn't. I've been seeing that game for a decade now from the alphabet soup crowd. I have no idea how or why any appraiser would think that way. It does so much harm to public trust.

 

[chad hampton]

I see your confusion. There are 3 sides.

 

[chad hampton]

I didn't realize that AMCs originate loans

They don't. But they have direct contact with the loan production staff. They are also not on the appraisal side. That's for the appraisers who hold licenses.