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AMC fees are not a requirement in the 3.6

NC Appraising

Elite Member
Joined
Apr 28, 2006
Professional Status
Certified Residential Appraiser
State
North Carolina
Taking the Appraisal Institute class on the URAR 3.6.

Per the teacher, the AMC section on fee disclosure is not required by the GESs. It's optional.

How convenient?
 
Why would that be a GSE requirement? Do you disclose your E&O premium, too? License cost? Rent? The force promoting the steep rise in the prevalence of AMCs in residential lending was legislated. Shouldn't that be the focus for a cure?
 
Taking the Appraisal Institute class on the URAR 3.6.

Per the teacher, the AMC section on fee disclosure is not required by the GESs. It's optional.

How convenient?
AMC fee / appraiser fee disclosure is at state level. Here in AZ there is a state law requiring the appraiser fee whem AMC is used.
 
Why would that be a GSE requirement? Do you disclose your E&O premium, too? License cost? Rent? The force promoting the steep rise in the prevalence of AMCs in residential lending was legislated. Shouldn't that be the focus for a cure?
Why would it hurt? Is there a law that prohibits the GESs to mandate this?

I'm all about transparency...just like the uad 3.6 should have a section to state the actual location the appraiser is located in...Certified in nc, but is physically located in New York.

They are the ones promoting saving borrowers money?

Full disclose....transparency? I never liked it when the AMCs on the LOE do not discuss the fee...Lil slimy....would hate for the borrower to find out how much we are making...

Nothing g to do with the uad 3.6...but

Truth in Lending (TIL) form for clearer, borrower-friendly information on final loan terms and costs, with lenders now responsible for its accuracy and delivery three business days before closing.


  • PDRs (which cost $200 on average), when used with ACE+ PDR, can save borrowers nearly $400 when compared to traditional appraisal reports (which cost $600 on average).
 
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Why would that be a GSE requirement? Do you disclose your E&O premium, too? License cost? Rent? The force promoting the steep rise in the prevalence of AMCs in residential lending was legislated. Shouldn't that be the focus for a cure?
“Do you disclose your E&O premium, too?” Yes. Clients want a copy of my binder in the report. The binder has my fee.

Regarding the AMC fee, I went to AMC rehab and am AMC sober for 6 years now!
 
it's optional now.. and has been... except in the few states where it is required.
I realize that.

I thought when the new form came out, it would be mandatory by the gses. Some AMCs prevent appraisers from disclosing what the appraisers fee was. Kinda goes against the truth in lending...in my opinion not 100% transparent.

There are some banks that mandate it now, even though it is not required by state law.

In my opinion, there are more positives than negatives for the new uad 3.6 to require fee disclosures when the reports are for the GSEs.

I simply do not understand the resistance on this matter? Let's do what is in the best interest of the borrower who is paying for the appraisal.

It is the borrowers money. Full disclosure.
 
Let's do what is in the best interest of the borrower who is paying for the appraisal.
It is the borrowers money.
That is not a part of the lending function, despite the noble notion. Anyone who relies on a lender or any of their henchmen (realtors, appraisers, government employees, title companies, etc) are damned fools. There is no substitute for thinking for yourself in any part of life. That is doubly important when (your) money is involved.

I used to try to help folks who were in too deep. One told me, on the brink of filing bankruptcy, that they had told the lender upfront, "Don't let us borrow too much money!" In another case, I appraised a small, third generation family farm. I ran into the banker (bank president) when doing my personal banking and he said, "Oh, you liked the XXXX farm, huh (meaning the value was sufficient to make the loan)." I said, "Yeah, its a nice little place. But I doubt they will be able to repay much of a loan." "Yeah, we know, but we are well secured." There is a family at the eastern end of the state that started out as poor ranchers. Then, they purchased the local bank. Through the years, their land holdings grew dramatically as their bank made loans that could not be repaid and they purchased the bank's REO properties. Now, they are a large, statewide banking chain and the family owns a few hundred thousand acres.
 
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