AMC Complaint

[Allan Gross]

Anyone here who can provide a link to file a complaint against an AMC in NY?

 

[J Grant]

Anyone here who can provide a link to file a complaint against an AMC in NY?

Wouldn't that be the NY State Board of Licensing Division, which would include both appraiser and AMC licenses?

 

[adballirock]

Allan, J Grant has it right. In New York, AMCs are registered with the Department of State's Division of Licensing Services, the same division that houses the Board of Real Estate Appraisal. The complaint form is on DOS's "Preliminary Statement of Complaint" page: https://dos.ny.gov/preliminary-statement-complaint-0. Fill it out and email it with your supporting documents to Complaints@dos.ny.gov, or mail it to the Complaint Review Office in Albany. It's worth confirming the AMC's registration first with the DOS licensee search for appraisal management companies.

A few things that help a complaint get traction:

- Stick to documents: the engagement letter, the emails or portal messages, the dates, and the fee quoted vs. what was paid.
- Tie it to a specific rule if you can. Pressure tied to the value, including holding up payment to get a different number, is an appraisal independence issue under Reg Z 1026.42. That carries more weight than a business dispute.
- If it's an independence issue on a mortgage loan, the ASC's Appraisal Complaint National Hotline (https://refermyappraisalcomplaint.ASC.gov, 877-739-0096) will point you to the right agency, which may include the lender's regulator. The hotline doesn't investigate itself; it refers you.

If you can share the general nature of the problem (no names), folks here can probably tell you whether it's mainly a DOS matter or a lender/regulator one.

 

[Allan Gross]

I appreciate that info. I Would like to file a formal complaint against one of the well known AMC's for customary fees. The basis of the complaint is simple. When an appraiser tries to change their profile to higher fees, they will actually remove the appraiser from the panel. Which seems to me to be a clear violation of the law, since there is a straightforward punishment for even requesting a higher fee.

 

[Trihard]

I appreciate that info. I Would like to file a formal complaint against one of the well known AMC's for customary fees. The basis of the complaint is simple. When an appraiser tries to change their profile to higher fees, they will actually remove the appraiser from the panel. Which seems to me to be a clear violation of the law, since there is a straightforward punishment for even requesting a higher fee.

Sounds like Rocket.

 

[J Grant]

I appreciate that info. I Would like to file a formal complaint against one of the well known AMC's for customary fees. The basis of the complaint is simple. When an appraiser tries to change their profile to higher fees, they will actually remove the appraiser from the panel. Which seems to me to be a clear violation of the law, since there is a straightforward punishment for even requesting a higher fee.

Go for it!

 

[Allan Gross]

I appreciate that info. I Would like to file a formal complaint against one of the well known AMC's for customary fees. The basis of the complaint is simple. When an appraiser tries to change their profile to higher fees, they will actually remove the appraiser from the panel. Which seems to me to be a clear violation of the law, since there is a straightforward punishment for even requesting a higher fee.

 

[Allan Gross]

Sounds like Rocket.

Maybe? But, don't you think that if they will have simple state complaints coming at them from every state, they will back off from such a practice? We appraiser are like sitting crying ducks and the entire industry knows it.

 

[Allan Gross]

Allan, J Grant has it right. In New York, AMCs are registered with the Department of State's Division of Licensing Services, the same division that houses the Board of Real Estate Appraisal. The complaint form is on DOS's "Preliminary Statement of Complaint" page: https://dos.ny.gov/preliminary-statement-complaint-0. Fill it out and email it with your supporting documents to Complaints@dos.ny.gov, or mail it to the Complaint Review Office in Albany. It's worth confirming the AMC's registration first with the DOS licensee search for appraisal management companies.

A few things that help a complaint get traction:

- Stick to documents: the engagement letter, the emails or portal messages, the dates, and the fee quoted vs. what was paid.
- Tie it to a specific rule if you can. Pressure tied to the value, including holding up payment to get a different number, is an appraisal independence issue under Reg Z 1026.42. That carries more weight than a business dispute.
- If it's an independence issue on a mortgage loan, the ASC's Appraisal Complaint National Hotline (https://refermyappraisalcomplaint.ASC.gov, 877-739-0096) will point you to the right agency, which may include the lender's regulator. The hotline doesn't investigate itself; it refers you.

If you can share the general nature of the problem (no names), folks here can probably tell you whether it's mainly a DOS matter or a lender/regulator one.

I don't see a box for AMC. I will assume its part of other. At least we appraisers are on top. As everyone knows, in NYS when the state comes at you, they don't focus on the complaint. They will send your file to a reviewer, who has no geographical competence and they will slap onto you, something about the work file rules. But they will never challenge your opinion of value, because the reviewer has no clue what the value is. We need to start fighting back.

 

[Surf Cat]

AMC's are right there at the bottom right...."Document Destruction Contractor"