J Grant
Elite Member
- Joined
- Dec 9, 2003
- Professional Status
- Certified Residential Appraiser
- State
- Florida
Asked and answered. D-F was a hit on the lenders and added prohibitions to their conduct. It didn't bestow any rights on anyone or create any new industries. AMCs had already existed in that form and sold bundled fees long before the HVCC..
"the stakeholders ( whatever that means) acted to capture profit" isn't even an argument. It's just a complaint.
Yes, the AMC's existed before HVCC, but had a very low market share wrt appraisals; they were mostly doing title work, and any appraisal management was a loss leader. The HVCC changed their market share overnight, and what used to be a small % charged as a bundled fee became almost half a fee split, going to third-party intermediaries, and an almost overnight vast shift of market volume. This saw appraisers lose their direct clients overnight, with the same assignments sent to themfrom an AMC at half the former fee.
Of course the stakeholders acted to capture profit !! What else was it? They could have opted for the lender ot pay a cost charge to the AMC instead of the fee split of a HUD bundled fee - you stated in this thread it is an option. An option they did not, and do not, take because it does not profit AMC middlemen, often affiliated with or owned as a division of a lender.