Class Valuation

[chad hampton]

You lost me when you started with the legally separated….How about we be a little more clearer than that? why does everything your side try to do always need disclaimers footnotes and asterisks by it to try to get your point across? The word and intent of the law is very clear.

 

[DWiley]

But as is usually the case, when people bend or outright break laws, it just takes a while to catch up. And you can see how the tide is starting to turn a little bit. It takes a while for regulators to wake up and say wait a minute, this wasn’t the intent of DF as it relates to Lending and appraising.

Believe it or not, I understand your point of view. But it is not as cut and dry as you seem to think. When I owned my firm in Nashville, the staff appraisers were employees (not contractors) who were paid salary and benefits. Were those folks "independent fee appraisers" who could be on an AMC panel? I think most would say, sure they were. That is essentially the model some AMCs follow with the staff appraisers to comply with the the law. I think there would be strong legal challenge to any attempt to pass laws saying that any entity cannot set up another company that does <fill in the blank with any legal activity>.

 

[J Grant]

The problem is not AMC compliance with the law, but rather that the law as originally made for the HVCC were changed to favor AMC itnersss and not protect the appraises, when the original laws and regulations of the HVCC were corrupted for a revised version /second source of C and R and a lender allowed to own an AMC etc was approved by regulators. We see how lobbying and $ can influence the laws and regulations in America and this is a shameful example.

 

[DWiley]

You lost me when you started with the legally separated….How about we be a little more clearer than that? why does everything your side try to do always need disclaimers footnotes and asterisks by it to try to get your point across? The word and intent of the law is very clear.

The guy that owned the AMC also owned several other things - restaurant chains, title companies, auto supply stores, etc. Those were separate companies. One could do the same thing with an AMC and an appraisal company.

 

[J Grant]

The AMC;s comply with the laws , appraisers are barking up the wrong tree. The real problem is that the laws are corrupt to favor the AMC and not protect the appraiser independence or C and R, since the AMC and lender lobbying changed the original well written regulations of the HVCCC and then Dodd Frank made it worse - one draconian regluaon after another that worked against the appraiser , and then people blame appraisers for caving on fees - of course if appraisers refused to cazve on fees the problem could resolve, but beaten down, deepare people working on thin profit margins simply are not capable of standing up to enormously funded and powerful banking and AMC companies. Of course, the appraisers who sell out and undercut on fees deserve scorn. But for many it is simply about survival

The fact that the control f volume in the hands of a small number of the larger AMC;s skews the normal supply and demand dynamic and makes it nearly impossible to obtain C and R, - while C and R works very well in the rest of appraisal work that does not go through the AMC and C and R works as intended in nearly every other profession.

When the HVCC prohibited direct ordering by individual loan officers, it put the appraisal demand into a small group and that gave them immense power over fees. The regulators who allow this should be investigated, IMO. u

 

[DWiley]

The fact that the control f volume in the hands of a small number of the larger AMC;s ...

You will never win with law makers if you keep asserting things that simply are not true. There are hundreds of AMCs (just check the state registrations) and none of them have enough market share to control things as you assert.

 

[J Grant]

You will never win with law makers if you keep asserting things that simply are not true. There are hundreds of AMCs (just check the state registrations) and none of them have enough market share to control things as you assert.

There may be hundreds of AMC's; however, if the work orders were audited, the finding would be that a far smaller number of the AMC's have a large volume of work.

I experienced it myself back when I did AMC work, I was signed up with dozens of them but only a handful had volume and those same large national or regional companies saw the same by nearly all appraisers across the country, with some exceptions possible.

The fact remains that it is easy to see the difference when the same or similar order is sent without an AMC as with an AMC. wrt the fee that the appraiser gets. The appraisal profession outside the mortgage lender AMC model is not affected.

The cost plus model is mainly seen in AMC that are owned by a lender for captive orders and is a better way with regard to the fee amount and selection.

 

[djd09]

Hiring staff appraisers is legal.

oh really...and the definition of independent includes but not limited to 'not controlled by others'....im sure that concept floats right on by

 

[chad hampton]

Appraisal Mills can hire appraisers to work all over the country if they want. AMC’s obviously that’s a different story. They are managing the appraisal process, they are not performing appraisals. Again, fairly simple concept. Stay in your own lane and we might be able to coexist.

 

[djd09]

you are leaving out the largest appraisal firm in the history of the world....the unlicensed mortgage brokers estimating value and their employers the gse's