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In response to my reflections last week on the issues with AMCs, I received an unusually high volume of comments. Thank you to everyone who took the time to write! The notes have been consistently critical of AMCs’ practices.
This week, I'm sharing a letter from a Chief Appraiser who asked for anonymity. With this individual’s permission, and final review, I edited it for this newsletter. Below is the first in a three-part series based on the letter:
“Your recent messaging about AMCs has prompted me to share my thoughts, based on my experience as a Chief Appraiser on the institutional side of this business.
Dodd-Frank has significantly impacted the residential appraisal industry over the past decade. The profession, once enjoyable, has become increasingly challenging and less fulfilling. The current environment has led me to reconsider my future in this field. The stress and risk no longer seem worth the financial rewards.
The financial crisis of 2008 made it easy to scapegoat appraisers, leading to the creation of firewalls between lenders and appraisers. While the intentions behind Dodd-Frank were commendable, the unintended consequences have been significant. I remember the days before Dodd-Frank when lenders would pressure you to meet their sales prices. Although those practices were problematic, the current system has created its own set of issues.
The appraisal industry's current system forces appraisers to bid against each other, driving down prices and increasing pressure to produce fast, compliant appraisals. This competitive environment often drives appraisers to work incredibly long hours, frequently seven days a week, to maintain competitive scorecards and continue receiving appraisal allocations from their clients. Appraisers must remain at the beck and call of AMCs to avoid negatively impacting their scorecards due to poor communication. Turning down too much work or being unavailable too often can result in significantly fewer assignments or none at all.
The consolidation within the AMC space has further complicated matters. A single negative decision from a review appraiser or Chief Appraiser can effectively end or limit an appraiser's income potential. Although AMCs might claim that they cannot easily remove an appraiser from their panel due to state regulations, it is easy to sideline appraisers by reducing their work radius and limiting their active orders to skirt such regulations and achieve the same effect. There are ‘Do Not Use’ lists that people in my position are well aware of, but not the appraisers who are on them. That’s a lot of power to put into the hands of very few people.
Dodd-Frank has led to the increasing average age of residential appraisers (by making appraisal a much less appealing career path), decreasing incomes, higher financial risk, unhealthy work-life balance, and, tragically, even suicides among residential appraisers. The relentless demands on residential appraisers, especially those doing primarily lending work, are overwhelming. They must be prepared to work seven days a week, responding to emails, text messages, and phone calls from overseas asking for statuses on appraisals all day and late into the night, including holidays. I knew an appraiser who received over 30 emails, calls, and texts asking for statuses on reports during the timeframe of performing just one property inspection. On top of that, the industry faces an approximate 40-50% revision rate, meaning no matter how good an appraiser is, they will never be good enough to avoid frequent revisions. Each lender, bank, and AMC has different rules, preferences, and opinions that must be tracked and remembered, putting appraisers at a constant disadvantage. Unlike the big AMCs, appraisers don't have access to advanced quality control technology powered by AI. If an appraiser's revision rate gets too high, their work can dry up overnight, leaving them with nothing.
Adding to this pressure, AMCs can get an appraisal review done for as low as $3 in India, further undermining the value of experienced appraisers who cannot compete with such low-cost ‘quality control’ alternatives.
However, while it's easy to demonize the AMCs, the pressure on price, turn time, and quality is out of their control for the most part. The AMCs, believe it or not, work on very thin margins and are at the beck and call of the lenders they serve, engaged in cutthroat competition against other AMCs for appraisal volume. Lenders typically work with multiple AMCs, and each is scored against the others based on turn time, price, and quality. This competitive pressure on AMCs translates into downward pressure on the cost and turnaround time for appraisals, while quality often becomes mere ‘safety theater’—pseudo-quality control.
Quality control has become focused on compliance with Fannie Mae, FHA, VA, and UAD guidelines, emphasizing completeness and accurate data entry over substantive review. Non-appraiser reviewers overseas, working at minimal cost, can check if the comparable GLAs bracket the subject's GLA, but they cannot assess if the comparables are truly similar in quality and condition to the subject property. They ensure borrower's names are spelled correctly but miss significant valuation issues, such as a $5,000 adjustment for an extra bathroom in a $10,000,000 home. If I, as a Chief Appraiser, decided to start reviewing adjustments thoroughly, I would get significant pushback. More thorough reviews that dig more into the substance of the report would lead to longer turn times, higher appraisal costs, and potentially lower appraised values, all of which would upset clients.
What can be done? That is the question, and I'm only writing all of this to you because you have a big enough voice that maybe you can do something.
I certainly can't. If I said anything at all in public, that would be the end of my appraising career. It's why no one really speaks up who ‘knows.’ Unless you're willing to change careers, you keep your mouth shut.
I could detail many other points here; I genuinely enjoy real estate appraising and pride myself on being a very hard worker. However, I also want the flexibility to prioritize my family without the constant fear of losing clients due to not responding to their messages 24/7 or to someone being cheaper by $20. From a business standpoint, this environment is too risky, and I need to focus my time, energy, and talent on more financially rewarding work.
I hope you can take action in putting the joy back into residential appraising, and I wish you the very best in your role as CEO of the Appraisal Institute. I'm always happy to help and answer any questions you might have.”
Part two will be posted next week, including suggestions and recommendations from the same author. In the meantime, please continue to share your thoughts and comments with me. I read and reply to each one.
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Yeah, you remember me and you and Evincere and Marion on Joan Trice.definition of independent...not belonging to a larger controlling group![]()