Closing Statements and AMC Fee

[Doug Wegener]

Yes, it is highly likely that closing statements will explicitly separate Appraisal Management Company (AMC) fees from the actual appraiser's fee in the near future.
While the Consumer Financial Protection Bureau (CFPB) historically treated this separation as optional—allowing lenders to bundle both into a single "Appraisal Fee" line item on the Closing Disclosure (CD) and Loan Estimate (LE)—a massive wave of regulatory, legal, and industry pressure in 2026 is forcing a shift toward mandatory unbundling. [1, 2, 3, 4, 5]

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Key Drivers Pushing for Separate Fees
The momentum to unbundle these fees comes from three major fronts:

• Active CFPB Regulatory Review: The CFPB recently closed a major Request for Information (RFI) regarding TRID and closing fee disclosures on August 10, 2026. A primary focus of this review is eliminating "hidden" consumer costs and restoring transparent line items. [1]
• High-Stakes Class-Action Lawsuits: Mortgage lenders and major AMCs are currently facing significant class-action litigation. The lawsuits allege that bundling fees tricks consumers into thinking the entire $800+ fee goes to the professional appraiser, when the AMC often pockets a substantial portion for administrative coordination. [1, 2, 3]
• Unified Appraiser Advocacy: National groups like the Appraisal Institute and the American Society of Appraisers have formally petitioned the CFPB to end the "Bundled Appraisal Fee" deception. They argue bundling distorts the free market and suppresses appraiser wages while keeping consumer costs artificially high. [1, 2]

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What This Means for Consumers and Lenders
If full unbundling is mandated by the CFPB or accelerated by court rulings, it will change how real estate transactions are itemized:

Aspect	Current Bundled Framework	Upcoming Unbundled Framework
Transparency	Borrowers see one flat "Appraisal Fee" (e.g., $800).	Borrowers see a split (e.g., $500 Appraiser / $300 AMC).
Cost Accountability	AMCs can compress appraiser fees without lowering borrower costs.	Consumers can challenge excessive administrative markups.
Lender Compliance	Allowed under traditional zero-tolerance TRID rules.	Lenders must adjust closing systems or face heavy compliance audits.

Many states already allow or require appraisers to list their direct fee inside the final appraisal report. However, the push in 2026 is designed to bring this exact clarity directly onto the very first pages of your federal mortgage disclosures before you sign. [1, 2, 3]

 

[glenn walker]

That's good but having been to many loan doc signings few to no borrowers care, and if asked they will be told the AMC does the quality control to make sure their appraisal meets up to the lenders standards.

We actually had a few borrowers say the appraisers fee should be less then the AMC fee. Either way it's good if separated but not going to change what appraisers get paid.

 

[Doug Wegener]

That's good but having been to many loan doc signings few to no borrowers care, and if asked they will be told the AMC does the quality control to make sure their appraisal meets up to the lenders standards.

We actually had a few borrowers say the appraisers fee should be less then the AMC fee. Either way it's good if separated but not going to change what appraisers get paid.

It does not make a lot sense then why the AMC's were so desperate to hide it.

 

[J Grant]

It's an improvement; however, the disclosure should happen upfront, at loan application, not later in the closing when it is too late for the borrower to object. Disloding it upfront would mean a trend toward cost plus instead of the flea market style fee bidding.

The better solution is no fee split at all; let the lender pay a cost for the AMC service and stop taking it out as a split of the appraisal fee.

 

[glenn walker]

It does not make a lot sense then why the AMC's were so desperate to hide it.

Honestly most don't spend anytime thinking about it and borrowers weren't complaining and the few that did were just wanting to close their loans. Remember they already paid the entire fee to the AMC so theres no shock at closing time.

Like I said I've no problem with better disclosure of fee's but it's not changing what the appraisers are paid. Many already do seperation of fees on disclosures so if the CFPB wants to make it manditory they should just do it and be done. No lawsuit's are required they have the power and authority to do it right now and why they don't is anyones guess.

 

[Surf Cat]

We actually had a few borrowers say the appraisers fee should be less then the AMC fee.

That's unfortunate.....borrowers never really understood the appraiser's analysis prior to the inspection, especially seeing them go through their property in a few minutes. They don't understand how much time the appraiser puts into putting it all together.

In regards to the main premise of the thread....separate disclosure is worthwhile for transparency, but this is not a compensation change for the appraiser.....It tells the borrower how the total charge was allocated..... it does not require the lender or AMC to pay the appraiser more.....unfortunately.

That said.....depending on how much tracktion this gets....it might be time for appraisers to step up.

 

[George Hatch]

It's an improvement; however, the disclosure should happen upfront, at loan application, not later in the closing when it is too late for the borrower to object. Disloding it upfront would mean a trend toward cost plus instead of the flea market style fee bidding.

The better solution is no fee split at all; let the lender pay a cost for the AMC service and stop taking it out as a split of the appraisal fee.

Separating the fee won't result in an increase of the appraiser's end.

 

[gregb]

Separating the fee won't result in an increase of the appraiser's end.

Who has claimed that separating the fee will result in an increase of fee to appraiser? We all know appraiser fees are about supply and demand and nothing to do with some breakdown on a HUD statement that is virtually a piece of paper filed away with no effect.