AMC asking for UAD 3.6 fees, what's everyone thinking?

[Essexfenwick]

The alternative being....................

Everybody drag your feet. Make it a bumpy ride. Point out that the new form discriminates against minorities and isolate the creators as racist. They pushed programs for diversity and then when they recruited enough minorities they forced less business and more effort on them like slavery. Then began pushing them out of business laughing about how they tricked them into courses and hope.

Fees haven't been determined as the new form appears to have discriminatory aspects which are being assessed and evaluated.

 

[jpowers]

The fee question is worth taking seriously because the workload is genuinely increasing. I've been going through
the 3.6 requirements and talking with experienced appraisers about what's changing, and as many of you have
rightfully pointed out, this is more work — and here's why. A 1004 had roughly 150-200 fields. The 3.6 dynamic
form has over 1,600 required or conditionally required fields. That's not a minor update.

There are entire new categories that didn't exist before — energy efficiency ratings, green certifications like
LEED, disaster mitigation features with installation dates, environmental conditions as structured data, and data
source attribution where the appraiser has to document exactly where each piece of information came from. The
energy and environmental stuff is genuinely new knowledge for most appraisers. Identifying a HERS score or
knowing the difference between types of renewable energy ownership isn't something that was part of the job
before. If that requires training, the cost of that training should be factored into fees too.

But here's the thing — more data going to the client means the end product is more valuable than what appraisers
were delivering before. That should mean higher compensation, not less. And the appraisers making the switch
early have real leverage right now. The supply of 3.6-capable appraisers is small, and so is the number of
software vendors that can actually produce quality 3.6 files. If AMCs need 3.6 work done and not many appraisers
are up to speed yet, early adopters are in a position to set their rates, not accept whatever's offered. That
window won't stay open forever, but right now the demand is growing faster than the supply.

As for the "death of the appraiser" concern — I'd argue the opposite. The 3.6 form asks for more professional
judgment, not less. Ceiling heights by room, per-room condition ratings, structured narratives — that's an
appraiser's expertise, not something a spreadsheet replaces. The software should handle the tedious data entry so
appraisers can focus on the parts that actually require their knowledge. If anything, this makes experienced
appraisers more valuable.

 

[J Grant]

The fee question is worth taking seriously because the workload is genuinely increasing. I've been going through
the 3.6 requirements and talking with experienced appraisers about what's changing, and as many of you have
rightfully pointed out, this is more work — and here's why. A 1004 had roughly 150-200 fields. The 3.6 dynamic
form has over 1,600 required or conditionally required fields. That's not a minor update.

There are entire new categories that didn't exist before — energy efficiency ratings, green certifications like
LEED, disaster mitigation features with installation dates, environmental conditions as structured data, and data
source attribution where the appraiser has to document exactly where each piece of information came from. The
energy and environmental stuff is genuinely new knowledge for most appraisers. Identifying a HERS score or
knowing the difference between types of renewable energy ownership isn't something that was part of the job
before. If that requires training, the cost of that training should be factored into fees too.

But here's the thing — more data going to the client means the end product is more valuable than what appraisers
were delivering before. That should mean higher compensation, not less. And the appraisers making the switch
early have real leverage right now. The supply of 3.6-capable appraisers is small, and so is the number of
software vendors that can actually produce quality 3.6 files. If AMCs need 3.6 work done and not many appraisers
are up to speed yet, early adopters are in a position to set their rates, not accept whatever's offered. That
window won't stay open forever, but right now the demand is growing faster than the supply.

As for the "death of the appraiser" concern — I'd argue the opposite. The 3.6 form asks for more professional
judgment, not less. Ceiling heights by room, per-room condition ratings, structured narratives — that's an
appraiser's expertise, not something a spreadsheet replaces. The software should handle the tedious data entry so
appraisers can focus on the parts that actually require their knowledge. If anything, this makes experienced
appraisers more valuable.

The more I learn about it, the more a 50% fee increase lines up with the increasing work, and that does not even include the increased scrutiny and liability, for every more precise data point or measurement we make leaves it open to challenge.

Whether we get that much increase or not, we should strive for as $ increase as feasible. The GSEs are pushing the AI-driven software because the churn and burn AMC staff or panel appraisers who compete on low fees will use it to gain time. However, if we give our agency over to AI, we are not appraising, and we are not following USPAP, which says that if AI or data AVM-type tools are used, the appraiser should be able to replicate the search and understand the techniques. Good luck trying to understand the algorithms.

The appraisers who take the time to manually verify this software will end up spending the same amount of time as if they had done their own searches from the start. We have MLS after all. The idea that AI in Aivre and similar programs can judge Q and C ratings from photos and pick the comps - that is the program the GSEs are endorsing. And they ain't endorsing it to help us save time, they are endorsing it because once enough appraisers use it, they can claim that appraisers are at that point acting as little more than data entry and decide that non-appraisers can use the programs just as well. They will call our replacements "trained data analysts". The precedent for it is their substitution of "data collectors" for appraisers in the inspection portion.

Just a heads up to the naive that believe the solution is to use these time-saving programs, which come at the expense of our agency.

Given the shrinking voume or orders and increased complexity of each order coupled with the increased inspection and reporting burdens of 3.6, whatever fee increase we ask for and get will still leave us underpaid. And dealing with entities who can and will use any small error or inconsistent data entries against us. Which is why newbies should A chllWhcis dother annn

 

[TerryRohrer]

..newbies should A chllWhcis dother annn

?

 

[Sandra Koutsopoulos]

Y'know, it is certain that completing the 3.6 form will cost an appraiser more time.... 1,600 entries? boggles the mind. Extra work SHOULD equal extra pay, but from WHOM? Consumers have not given the okie-dokie to paying an extra $300+ to have their privacy invaded, time wasted just to get a mortgage. Closing costs are high anyhow, which can be a barrier for some.

Realtors have no idea about this EITHER. I've recently been attending a local association's meetings, and they are clueless and in disbelief about the extent to which stuff will be documented and potentially disbursed to others without owner's knowledge nor agreement. A vacant house? Sure, no problem. A house where ppl actually live, with their accoutrements of life, art, furnishings, evidence of who (from kids to infirm elderly) may live there is an invasion of privacy, let alone having to fund that invasion with a higher appraisal/inspection fee. It's just too d@mn much! And all of that for the robots to put in their databases in the cloud for others' purposes.

...Forensic detectives to build a case?... The minutia of information required is not justified for purposes of approving a mortgage. Big Brother wants to know too much, and for what purposes might it be implemented in future? Privacy. Precious.

 

[djd09]

1,600 entries...there goes cheap and fast

 

[Alsie35]

The fee question is worth taking seriously because the workload is genuinely increasing. I've been going through
the 3.6 requirements and talking with experienced appraisers about what's changing, and as many of you have
rightfully pointed out, this is more work — and here's why. A 1004 had roughly 150-200 fields. The 3.6 dynamic
form has over 1,600 required or conditionally required fields. That's not a minor update.

There are entire new categories that didn't exist before — energy efficiency ratings, green certifications like
LEED, disaster mitigation features with installation dates, environmental conditions as structured data, and data
source attribution where the appraiser has to document exactly where each piece of information came from. The
energy and environmental stuff is genuinely new knowledge for most appraisers. Identifying a HERS score or
knowing the difference between types of renewable energy ownership isn't something that was part of the job
before. If that requires training, the cost of that training should be factored into fees too.

But here's the thing — more data going to the client means the end product is more valuable than what appraisers
were delivering before. That should mean higher compensation, not less. And the appraisers making the switch
early have real leverage right now. The supply of 3.6-capable appraisers is small, and so is the number of
software vendors that can actually produce quality 3.6 files. If AMCs need 3.6 work done and not many appraisers
are up to speed yet, early adopters are in a position to set their rates, not accept whatever's offered. That
window won't stay open forever, but right now the demand is growing faster than the supply.

As for the "death of the appraiser" concern — I'd argue the opposite. The 3.6 form asks for more professional
judgment, not less. Ceiling heights by room, per-room condition ratings, structured narratives — that's an
appraiser's expertise, not something a spreadsheet replaces. The software should handle the tedious data entry so
appraisers can focus on the parts that actually require their knowledge. If anything, this makes experienced
appraisers more valuable.

You ever completed an appraisal? Or are you just a "Tech-Bro"with a thin talent stack and limited life experience, who's never had a real job, who's done nothing in his life but sit at a keyboard, and who's now come here to pontificate from "on high"? Enquiring minds want to know. Do tell us.

(Might be useful to your 'street cred' to add what military branch you served in, what theater of operations you were deployed in and what small business employing others you've created in your time ... if you did, say it ... because it would help people to take you seriously ... if you did none if those things ... 'go fly a kite' ... (I'd like to use the type of lingo we used on deployment, but I'm afraid you might faint) ...

 

[Surf Cat]

You ever completed an appraisal? Or are you just a "Tech-Bro"with a thin talent stack and limited life experience, who's never had a real job, who's done nothing in his life but sit at a keyboard, and who's now come here to pontificate from "on high"? Enquiring minds want to know. Do tell us.

(Might be useful to your 'street cred' to add what military branch you served in, where you were deployed and what small business employing others you've created in your time ... if you did ... would help people to take you seriously ... otherwise ... ... just sayin ...)

Me-Ow...sheesh

 

[Surf Cat]

1,600 entries...there goes cheap and fast

Here’s what's funny.... after going from 200 entries to 1,600 entries.... you're still going to get stipped and ROV requests

 

[GWISC]

I found an article that spells out fee discussion. Turns out, it is not a Truth and Lending rule, but rather an FTC reg. Here is the article. Below is a quote that illustrates that advertising our prices is not discussing them.

I find this relevant as the header of this is asking us what we think when the AMC's ask us what our fees will be for UAD 3.6.

Quote from Article attached below quoting Joseph Bauer, a professor of law at Notre Dame Law School:
As a foundation for understanding what kinds of discussions could be in violation of antitrust law, Bauer explains that it is unlawful to make an agreement that will restrain trade. Therefore, an agreement that is always unlawful is one that involves an agreement among competitors on price. But as the saying goes: it’s complicated. “One example I use is what my aunt asked me many years ago regarding the price of gasoline,” Bauer said. “As she drove down the street she saw the signs from three different gas stations selling gasoline at the same exact price. She said it didn’t appear they were competing with each other and isn’t that against the law?” The answer, Bauer says, is not necessarily.

“If all you have are independent behaviors, or even inter-dependent behavior, that’s not unlawful,” Bauer says. “What would be unlawful, however, is if the gas station owners talked to each other and agreed that tomorrow morning they were all going to raise their prices to $2.05 per gallon. However, if one owner raises his price to $2.05 independently and the others look out their windows, see the new price, and independently raise their prices to $2.05, that is not unlawful. The key question, which is a mixed question of law and fact, is whether they are in agreement,” says Bauer.

This same concept applies to a multitude of professions, including real estate appraisers and agents/brokers. “If appraisers who are competitors get together and decide they will charge a fee of $X, or if real estate agents all agree that they will charge a commission of 6 percent, that’s unlawful. However, if they each decide independently that $X is a fair price, or that 6 percent commission is a fair commission and that they can’t cover their overhead with less than $X, then that is lawful,” says Bauer.

Talking Fees and Antitrust

The danger comes when one takes actions that could be seen as inviting agreement.

www.workingre.com