Appraisal Foundation

[Zoe]

Boys and girls are playing.

● Post-Dodd-Frank changes to assignment and disclosure. Prior to Dodd-Frank, lenders typicallyengaged small independent appraisal firms directly. The firm would spread the work among itsappraisers and trainees. Implementation of Dodd-Frank's appraiser-independence provisions drovebroad adoption of Appraisal Management Companies (AMCs) as the intermediary, and over time theseAMCs began assigning orders directly to individual appraisers rather than to the firms that employthem. Fee transparency also changed. The single line item the consumer sees on the ClosingDisclosure as an "appraisal fee" today bundles the AMC's management fee with the appraiser'scompensation. Dodd-Frank requires lenders to compensate appraisers at "customary and reasonable"rates (15 U.S.C. § 1639e). In the most recent industry survey, 73% of responding appraisers reportedno increase in their fees in the 15 years since customary-and-reasonable took effect (OctoberResearch, 2025 Voice of the Appraiser, 15th annual survey). The headline "appraisal fee" theconsumer pays has grown over those 15 years; the portion reaching the appraiser has not.

 

[Zoe]

3. Increase transparency in the consumer-facing "appraisal fee." Federal agencies could explore consumer-facing disclosure: separately presenting the AMC management fee and the appraiser's compensation on consumer disclosure documents and in supervisory reporting. A narrow disclosure change has no fee-setting implications and improves insights into the economics of entry into the profession.

 

[Zoe]

Do you have any thoughts? I would love to hear your thoughts on what Appraisal Foundation posted as white paper I assume.

I could call Joan Trice but she won't answer. @DWiley might have opinion on white paper. He used to work for AMC.

 

[Carnivore]

How does Some one who is thinking about entering the profession find find out what the deal is. . ie high schools have career day. Students go to that and their our counselors and business/corp their to help them decide on a path. All my young married people friends with kids have never ask me. One guy who is my neighobr ask me about it' WellI don't like the guy. so Told him don't bother fee'ss are low and their is to much competition. Plus he would want me to be his super NO Way

Tell me.WHO and tell m WHY d id they come up with parea? NC just adopted it

 

[Tom4value]

Contrary to what some appraisers think, AMCs do not have a monopoly on appraisal work. I have several….ok, 9 clients. Only one is through an AMC and they are so user friendly and pay so well, I forget they are an AMC. Six use portals. Yes, there is a fee to use them but the clients pay extra to cover this. The other two I deal with directly. That means 100% of the fee goes to me as it is a “pass though fee”, which means the lender is not allowed to mak any money on it. What they charge the borrower goes to me.

 

[Zoe]

Contrary to what some appraisers think, AMCs do not have a monopoly on appraisal work. I have several….ok, 9 clients. Only one is through an AMC and they are so user friendly and pay so well, I forget they are an AMC. Six use portals. Yes, there is a fee to use them but the clients pay extra to cover this. The other two I deal with directly. That means 100% of the fee goes to me as it is a “pass though fee”, which means the lender is not allowed to mak any money on it. What they charge the borrower goes to me.

That is not the way it is in many cases. The focus with complaints is on the borrower. Sometimes the borrower gets charged $1,500 or whatever for the appraisal and the appraiser gets paid $300. That in essence is what will break the camel's back for bundled and commingling of fees. The AMC and Bank keep the profits from the borrower.

They don't have a monopoly. It is market structure related. They have an oligopsony in some cases with certain lenders and appraisers. The key to antitrust violation is market power on price due to market structure.

The lender and AMC do have market power on price in certain markets due to market structure. Don't look at it from an appraiser standpoint. Look at it from a borrower standpoint.

If fees were separated on truth in lending disclosures, it would clean up the market structure issues. AMCs would operate in one market and compete against each other. Appraisers would operate in different market.

It would be transparent to the borrower on truth in lending disclosures.

 

[Zoe]

By the way, another impact from commingling of fees is "fastest and cheapest" when lender is selling loan to a GSE.

Lenders that keep a loan in house on their books don't typically pursue fastest and cheapest appraisers. Instead they look for competency because they have more skin in the game to lose.

They have to answer to regulators and stockholders and depositors and customers. They don't want "fastest and cheapest". The APPRAISAL fee they disclose on truth in lending disclosures is fee they pay the APPRAISER..

 

[Zoe]

Contrary to what some appraisers think, AMCs do not have a monopoly on appraisal work. I have several….ok, 9 clients. Only one is through an AMC and they are so user friendly and pay so well, I forget they are an AMC. Six use portals. Yes, there is a fee to use them but the clients pay extra to cover this. The other two I deal with directly. That means 100% of the fee goes to me as it is a “pass though fee”, which means the lender is not allowed to mak any money on it. What they charge the borrower goes to me.

I like you btw. Don't make me mad like Joan Trice. I will haunt you. LOL

I miss my girlfriend Joan. We don't talk anymore.

 

[Zoe]

For the record, I appreciate the Appraisal Foundation taking a stance for separation of fees on truth in lending disclosures. You can agree or disagree.

I have open door policy. Your welcome.

 

[Francois K. Gregoire]

Boys and girls are playing.

● Post-Dodd-Frank changes to assignment and disclosure. Prior to Dodd-Frank, lenders typicallyengaged small independent appraisal firms directly. The firm would spread the work among itsappraisers and trainees. Implementation of Dodd-Frank's appraiser-independence provisions drovebroad adoption of Appraisal Management Companies (AMCs) as the intermediary, and over time theseAMCs began assigning orders directly to individual appraisers rather than to the firms that employthem. Fee transparency also changed. The single line item the consumer sees on the ClosingDisclosure as an "appraisal fee" today bundles the AMC's management fee with the appraiser'scompensation. Dodd-Frank requires lenders to compensate appraisers at "customary and reasonable"rates (15 U.S.C. § 1639e). In the most recent industry survey, 73% of responding appraisers reportedno increase in their fees in the 15 years since customary-and-reasonable took effect (OctoberResearch, 2025 Voice of the Appraiser, 15th annual survey). The headline "appraisal fee" theconsumer pays has grown over those 15 years; the portion reaching the appraiser has not.

It looks as though posts without a complaint about The Appraisal Foundation or another target of the day do not generate much initerest. Thank you for posting this. Seems a shame few have taken the time to read.