AMC purpose

[djd09]

hip hip hooray 15th st...

 

[George Hatch]

So what’s the difference between AMC License and an appraisal license?

If they’re the same thing, I’m fine with that. All I’ve ever requested was that there be a level playing field. If AMC is allowed to employ staff appraisers and effectively be an appraisal company, Which effectively eliminates the appraisal side of the third-party Then I should be able to go directly to lenders and offer my services as AMC and appraiser

How can anyone be against a level playing field?

There is no requirement for a 3rd party. I don't know why you would even think that. You already know lenders are allowed to do direct engagement and you surely have (or at least had) some direct engagement clients in the past.

How can

"lender allowed to do direct engagement" ​

and​

"lender required to use a 3rd party engagement"​

coexist at the same time in the same discussion?


And yes, you're 110% allowed to compete directly with the AMCs and do what they do or to undercut their fees or do appraisals and AMC at the same time. I don't know why you would think appraisers can't do that. The AMCs ain't special. They don't have some protected status in the market for services.

 

[JM2187]

What seems to be missing in this coversation is the fact that the lenders do not want to deal with the drama of getting appraisals done, instead they want to order them like a simple order on Amazon, and they can't do that directly when they are lending nationally.

The AMC ideally works through the pain points behind the scenes, finding appraisers, negotiating fees, explaining client requirements, explaining USPAP/Fannie Mae/FHA etc. guidelines ad nauseum to appraisers who should know better (ie. "No, ANSI really does say walk out basement square footage can't be in the GLA, even if it is just some dirt on a side wall" that was today for me), explaining client guidelines again, explaining forms, formats, USPAP reporting requirements again, UCDP warnings, GPAR, on and on, to sometimes very unfriendly appraisers. Then add on navigating lender portals, uploading this and that, renaming files and invoices, client review checklists, AIR certificates, excel spreadsheets, on and on.

Oh, and then, once that's all done, dealing with borrower ROV requests, prior appraisals, second appraisals, value reconcilation, jumbo loans, matching up photos and deeds and zoning, construction bids and sales histories, trying to figure out who is right and who might not be and providing solid answers.

The lenders simply don't want to deal with all of that, and frankly the pain point appraisers are NEVER even looking at this forum, if you're reading this, it's not you. They already know it all, no reason to look here.

And before you say it, paying a higher fee is no guarantee of any kind of service, professionalism, or quality. If it was that easy, then there would be no need for AMC's.

 

[Surf Cat]

I’ve seen many of those prohibited acts be used in direct violation of what the law actually says.

Hey.....undocumented immigrants weren't supposed to be here in the U.S. and be employed either yet....they have been.....for decades.

No biggie for  AMCs to employ appraisers as staff as opposed to maintain a panel or network of independent appraisers as originally intended.....they lobby bro...laws shmaws....

 

[J Grant]

What seems to be missing in this coversation is the fact that the lenders do not want to deal with the drama of getting appraisals done, instead they want to order them like a simple order on Amazon, and they can't do that directly when they are lending nationally.

The AMC ideally works through the pain points behind the scenes, finding appraisers, negotiating fees, explaining client requirements, explaining USPAP/Fannie Mae/FHA etc. guidelines ad nauseum to appraisers who should know better (ie. "No, ANSI really does say walk out basement square footage can't be in the GLA, even if it is just some dirt on a side wall" that was today for me), explaining client guidelines again, explaining forms, formats, USPAP reporting requirements again, UCDP warnings, GPAR, on and on, to sometimes very unfriendly appraisers. Then add on navigating lender portals, uploading this and that, renaming files and invoices, client review checklists, AIR certificates, excel spreadsheets, on and on.

Oh, and then, once that's all done, dealing with borrower ROV requests, prior appraisals, second appraisals, value reconcilation, jumbo loans, matching up photos and deeds and zoning, construction bids and sales histories, trying to figure out who is right and who might not be and providing solid answers.

The lenders simply don't want to deal with all of that, and frankly the pain point appraisers are NEVER even looking at this forum, if you're reading this, it's not you. They already know it all, no reason to look here.

And before you say it, paying a higher fee is no guarantee of any kind of service, professionalism, or quality. If it was that easy, then there would be no need for AMC's.

Thanks for your perspective.
It is all true except the last - while a higher fee is no guarantee, a lower fee precludes many competent appraisers who refuse to do AMC work.

I fully understand all the admin that the AMC performs for a lender. The lender then should pay a cost to the AMC for the AMC management function. The problem for appraisers is that the AMC, instead of charging their lender customer a cost for their service, like every other business and profession does, the AMC offers free of cost service to the lender and gets compensated from a split of the borrower covered appraisal fee ( result is the appraiser makes far less $ doing AMC orders. This financially harms appraisers and also harms borrowers and investors, as more competent and experienced appraisers may be passed over for a lower bid or fee.)

Sum up: The lender should pay the AMC cost fully separated from the covered appraisal fee, which should go to the appraiser the way it does when no AMC is used.

I am aware that the AMC getting compensated from a split of the appraisal fee (bundled fee ) is legal. But something being legal is not the same as it being ethical. Slavery was once legal, and so was child labor. I am aware of the overly dramatic comparison, but the point is that certain practices that were legal in a given time are later overturned .

 

[George Hatch]

There is no argument as to what appraisers think the lenders "should" do. That was never in dispute. What is completely lacking in this running gunbattle are any suggestions or ideas on how coerce, force or otherwise manipulate these lenders into acting contrary to their own preferences. Contrary to what they perceive to be in their own best interests.

Speaking for myself (only) I freely admit that I have no idea how to force these lenders to do what we want them to do. After 15 years of this all of our complaints about their greed and avarice hasn't worked, leastwise not so far.

 

[DWiley]

Then I should be able to go directly to lenders and offer my services as AMC and appraiser

Why would you think you cannot do that? I know multiple appraisers in Nashville who hold both individual appraiser credentials and AMC credentials. As noted many times, there are hundreds of AMCs and many of them are very small , operated by a single appraiser in a local market. One appraiser I have known for a very long time still does appraisals, but he also acts as an AMC for a local credit union.

 

[djd09]

Why would you think you cannot do that? I know multiple appraisers in Nashville who hold both individual appraiser credentials and AMC credentials. As noted many times, there are hundreds of AMCs and many of them are very small , operated by a single appraiser in a local market. One appraiser I have known for a very long time still does appraisals, but he also acts as an AMC for a local credit union.

so they can just send the appraisal to themselves...

 

[chad hampton]

Why would you think you cannot do that? I know multiple appraisers in Nashville who hold both individual appraiser credentials and AMC credentials. As noted many times, there are hundreds of AMCs and many of them are very small , operated by a single appraiser in a local market. One appraiser I have known for a very long time still does appraisals, but he also acts as an AMC for a local credit union.

And you see no issues with that? How in the hell is that in the spirit and intent of AMC legislation?

But im not surprised you know guys like that.

 

[chad hampton]

so they can just send the appraisal to themselves...

They shouldn’t stop at being 2 of the 3 parties. Go for all 3.