AI will be supporting VA fee schedule - needs input!

[KenAZ]

Um, no. Like it or not many lenders have added to the appraisal fee (and just about every other fee) for many years and the practice is permitted.

They are actually not permitted to takc other expenses and wrap it into the appraisal fee, even though they have been doing it for over a year. The big box banks that own AMC's are required to disclose that they own the AMC and are taking a cut of the appraisal fee.

They haven't been.

HUD requires that the entire appraisal fee goes to the appraiser. I can name about 50 AMC's that have not been following that requirement.

 

[Non Sequitur]

They are actually not permitted to takc other expenses and wrap it into the appraisal fee, even though they have been doing it for over a year. The big box banks that own AMC's are required to disclose that they own the AMC and are taking a cut of the appraisal fee.

They haven't been.

HUD requires that the entire appraisal fee goes to the appraiser. I can name about 50 AMC's that have not been following that requirement.

You think you're correct but the regulators have allowed it and continue to allow it. It's the regulators who determine the meaning of the language in the regulations, not those who think they know what it says.

One would think HUD announcing R&C is a business decision would have taught appraisers something, but noooooo. Here we go again with the exception that R&C will be law. Fool me once, shame on you; fool me twice.......

And all we hear are crickets in place of thread after thread and article after article rallying the troops in support of HR 4173. Would it be to much to ask for them to grace us with their presence?

http://www.orep.org/wordpress-2.7/wordpress/?p=325

 

[Karl]

No one, but the Appraiser actually allows it!!

 

[prasercat]

AI, et al message to Fed,

The Appraisal Institute was joined by the American Society of Appraisers, the American Society of Farm Managers and Rural Appraisers, and the National Association of Independent Fee Appraisers.

The Dodd-Frank Act contains a provision requiring “customary and reasonable” fees be paid to appraisers to reflect what an appraiser would typically earn for an assignment absent the involvement of an appraisal management company. Under the Act, evidence for such fees may be established by objective third-party information, such as government agency fee schedules, academic studies and independent private sector surveys.

The groups brought to the attention of the Fed the divergence between fees paid to appraisers through AMCs and those retained directly by financial institutions. “While some AMCs pay full fees and charge for their services on a ‘cost-plus’ basis, many do not. Many of our members report having to accept reduce fees by as much as 50 percent since the inception of the Home Valuation Code of Conduct,” the groups wrote.

The groups pointed to the Department of Veterans Affairs’ Appraisal Fee Schedule as an appropriate guide. The schedule, which is developed through surveys of local appraisers approved on the VA Fee Panel, “is an appropriate standard to be directly referenced in the Interim Final Rule,” the groups said. The groups also recommended that any privately developed surveys be prepared in accordance with generally recognized research standards to enhance credibility.

The letter reiterates points the groups made on a Sept. 8 conference call with Federal Reserve Board staff. The Fed is expected to release the Interim Final Rule implementing the appraiser independence standard by Oct.19.

 

[AnonApprsr]

VA Fees are slightly low for MA, but only by 50 bucks or 75 bucks.

 

[prasercat]

VA Fees are slightly low for MA, but only by 50 bucks or 75 bucks.

What about issues of complexity? Does VA have a policy not to deviate from the schedule? I couldn't get on VA as they were closed to new members - I don't know how they work.

I found this on the internet for VA: http://www.benefits.VA.gov/homeloans/docs/denver_fee.pdf

===================================================

Fee Schedule July 2009
State , Single Family, Duplex, Triplex, 4 Plex, Condo, *Liquidation Appraisals, Repair Inspection​

Alaska $625, $800, $850, $900, $625, See Below $100
Colorado $400, $600, $625, $650, $400, See Below $100
Idaho $450, $650, $675, $675, $475, See Below $100
Montana $500, $600, $625, $650, $500, See Below $100
Oregon $500, $600, $625, $650, $500, See Below $100
Utah $425, $650, $650, $650, $425, See Below $100
Washington $500, $650, $750, $800, $500, See Below $100
Wyoming $500, $600, $625, $650, $500, See Below $100​

NOTE: The above indicated fee for single family, duplex, triplex, 4-unit, and condo appraisals
includes a $50 VA Nationally approved fee for the completion of the 1004MC form. This form is required on all VA appraisals, to include liquidation appraisals. (This fee is effective for appraisals with an effective date of August 1, 2009 or later).​

*If the appraisal is completed for liquidation appraisal purposes, appraisers are authorized to charge an additional $50 fee above the fee indicated for the particular type of appraisal shown above. (This fee is effective immediately)​

Any allowable mileage fee is calculated at $.50 per mile.

======================================================================

So a base fee for VA now includes the 1004MC fee, which caused a $50 increase from prior fees. My base fee then in Colorado would be $400. I just wonder about the luxury homes and unusually complex work.

 

[KenAZ]

What about issues of complexity? Does VA have a policy not to deviate from the schedule? I couldn't get on VA as they were closed to new members - I don't know how they work.

They label it the maximum fee, but I have never seen any VA appraiser accept or be offered a lower fee than the schedule. The AI letter addresses this also.

The VA appraisal is a basic appraisal that requires three comps. If you want to provide more, you can.

My opinion is that the VA fee be for basic appraisals that follow FNMA, VA or even HUD guidelines. If the client wants 4 sales and 3 listings, then they pay $25 per comp. If the appraiser supplies extra comps, because he feels it is necessary, then those comps are free.

If the client gets involved with comp selection (i.e. Distances, 1 in subdivision and 1 outside subdivision, only with 3 months, etc.) that would also require higher fees due to increased complexity and SOW.

If the client requires aerial maps, CMA, MLS printouts, etc, then $10 per extra page. You want 20 pages of photos? OK, an extra $200. (Oh NOW you want me to all in a sudden use the 12 photos per page photos sheets?)

You want the absurd HVCC comment, and a comment that the electricity is on, and the A/C is working, and the appraiser is geo-competent, etc. Sure, $10 per required comment.

The base fee is pretty much settled. VA rates are the defacto rates. Now we need to worry about the added fees that we have not been collecting over the last 1.5 years.

Clients have been taking advantage of the AMC's willing to do anything to get the assignment, and making much more requirements without paying for them. As a result, appraisals take at least double the time to complete.

 

[Michigan CG]

While I find the VA fees to be a little low in comparison to my typical fee I think one should consider the requirements of the typical AMC.

Some obviously have no review staff seeing what passes through their "quality control" (hello Wells Fargo, your appraisers are idiots). It does not appear that some of these AMCs have any relevant reviewing, but rather stips for certain items checked by a person who only needs to have a GED and a "license (trainee license is ok)".

Some AMCs have stringent requirements that are beyond what I will put in a 40 page residential report for which I am doing for litigation.

The lending institutions and AMCs would do well for themselves to have a standardized list of requirements. I cannot imagine working for 10 AMCs with 10 different sets of rules for less than $500 per report.

The AMCs are telling appraisers that certain things are required by the lender yet there are multiple posts on here where the appraiser is working for a different AMC but the same lender and the requirements are different.

These AMCs are lying to the appraiser only to show they are giving quality to the client. It is also not uncommon for the AMC to lie about USPAP conditions which they do not understand.

If an AMC wants to be in the appraisal business they should take the minimal effort to understand the business and the USPAP requirements.

The AMC model does not understand that the typical response to a report that is turned in for lending purposes is "thanks for the report, we issued payment for your services".

The AMC model does not understand that if they give a checklist of what they need and give it to the appraiser and pay them for the additional requirements they will get what they want.

The AMC model does not understand that the cheap guy is most likely not the best guy. The AMC model does not understand that the checklist is not really a review.

The AMC model of lying to their clients will catch up to their clients and the American consumer.

The AMC provides no service to the appraiser (no matter what Shurman says) and the intent of the AMC is to be a firewall and nothing else.

The AMC model will change in the next 90 days. They have to.

=====================================

So considering the current state of the AMC assignment and the lies, requirements and reviews by clueless people it is my opinion that the VA schedule is fair to VA appraisers but not for appraisers working for idiots who do not know what they do not know. I think the AMC fee should be 1.5X the VA fee which is again taking advantage of the American consumer.

Until then I will continue to work for the local lender, the hard money lender, the private client and the attorneys. I will take referral work and will turn down the AMC BS. But since I am approaching empty nest syndrome I will continue to review the idiot AMC appraiser reports hoping that someday the client will sue the AMC for hiring and then claiming to review the report and claim the report is credible and USPAP compliant.

Some day an AMC will get sued, and the bank client will not be able to back them up.

 

[prasercat]

Just got this email from AI and I copied the applicable portion. - Oops, looks like I made a goof - DON'T!

Sheesh, now they tell me..... I removed the link on the initial post of this thread.....

====================
Message body removed...................

Best regards,
Appraisal Institute Research and Strategic Planning Department

Please note: This survey invitation is for your use only. Please do not forward this message or the link to the survey to anyone because this may allow individuals to take the survey that are not part of the randomly selected sample for this study. Responses from participants not part of the controlled sample could undermine the reliability of the survey findings.

 

[OSU Beavers]

Here is the whole country http://www.benefits.VA.gov/homeloans/fee_timeliness.asp