Customary and reasonable fees - 90 days

[Mike Kennedy]

"It's not the AMCs that are the problem"........ :new_smile-l:

TWO PART SERIES- AUTHOR'S OPINION

http://appraisalnewsonline.typepad....nt-rants-the-AMC-discussion-continued.html#tp

http://appraisalnewsonline.typepad.com/appraisal_news_for_real_e/runts_rants/#tp

 

[Elliott]

Ken V said, "I've offered my opinion that I can see a 5-10 percent charge to the appraiser due to the efficiencies that the AMC can provide to the organized and professional appraiser or appraisal firm."

The problem isn't the 5-10-20-30 percent charge or the two tiered profession.
The problem is AMCs are part of the 5 lender/5 AMC collusion. The Old LSi
was a service. AMCs don't provide efficiency, they are very inefficient from
an appraiser's standpoint. The reason they are inefficient is that all have
data collection (stealing) systems to push their AVM products. PDFs were
efficient. Getting a fax or email you have a message on a website isn't
efficient and doesn't constitute 'independence.'

 

[LACKLAND27]

$1,000 for a 1004

Lackland,

Your missing the point that when it comes to appraisals for Lending, what the appraiser has been paid is what the appraiser has been paid,

the customary and reasonable fee is what the borrower has paid, as warrantied by HUD that the borrower would not pay more than C&R.

Do not confuse these two issues, as they are important distinctions in FEDERAL POLICY and the big egos of appraisers want to make believe we are the ones that control the customary and resonable fee when in fact the lenders do.

There is no Free Market for C&R Appraisal Fees, because the lenders set them and then charge the borrowers. The borrower's do not get to negotiate it or pick the Appraiser or pick the AMC for that matter. All of this is verticle control of the money by the lenders.

On the contrary as I noted the consumers are willing to pay these fees. If they were to unreasonably high they would go to a different lender. The Lenders are still in competition with each other and have to price their fees at what the market will bear. So the lenders and the AMCs have shown the market will bear a fee for a typical 1004 up to $550.

And just to make myself clear, I no longer do lending work since: A- I refuse to work with phone monkeys. B- The current liability is far too high in this economic climate.

So I have no egomaniacal reasons influencing my opinion. Of course there is some influence from the big lenders on fee. But the lenders and AMCs still have to do business in a free market and therefore at the end of the day the final fees charged for an appraisal will be what the market will bear. Otherwise they would be charging upwards of $1,000 for a 1004.

 

[Meandering]

On the contrary as I noted the consumers are willing to pay these fees. If they were to unreasonably high they would go to a different lender. The Lenders are still in competition with each other and have to price their fees at what the market will bear. So the lenders and the AMCs have shown the market will bear a fee for a typical 1004 up to $550.

Thank you Lackland,

We agree.

HUD says the borrower cannot be charged more than C&R Appraisal Fee as a combined Fee including AMCs. Now the law is that WE must get the C&R Fee and that fee is up to $550, not $300 or $350.

You should send this to Joan Trice for her survey.


.

 

[Mike Kennedy]

http://appraisersforum.com/showthread.php?t=171608

 

[Non Sequitur]

HUD says the borrower cannot be charged more than C&R Appraisal Fee as a combined Fee including AMCs. Now the law is that WE must get the C&R Fee and that fee is up to $550, not $300 or $350.

Considering everyone knows the fee did include AMC charges and the very loud cries of "AMCs are ripping appraisers/consumers off" how in the world can you justify C&R is $550? Are you going to back track and say $550+ wasn't a rip off? And FWIW what HUD says and what HUD enforces usually don't match.

Don't get greedy. AMC appraisers should be happy with anything over what they're getting now. As for the rest of the appraisal profession we'll have to deal with the unexpected consequences of this mess of a law while the AMCers will be happy just popping out forms all day.

You should send this to Joan Trice for her survey.

Good luck with that.

 

[LACKLAND27]

Considering everyone knows the fee did include AMC charges and the very loud cries of "AMCs are ripping appraisers/consumers off" how in the world can you justify C&R is $550? Are you going to back track and say $550+ wasn't a rip off? And FWIW what HUD says and what HUD enforces usually don't match.

Don't get greedy. AMC appraisers should be happy with anything over what they're getting now. As for the rest of the appraisal profession we'll have to deal with the unexpected consequences of this mess of a law while the AMCers will be happy just popping out forms all day.
Good luck with that.

$550 may be a little bit high but $450 is reasonable after factoring in the increased cost such as E&O insurance, car insurance, gas, and office supplies. These items haven’t gotten any cheaper, nor has the time to produce a quality appraisal gone down. With increased expenses and more time required to complete each assignment a fee of $450 is reasonable and $550 is not ridiculous.

However when and AMC charges $550 and pays the appraiser $150 and requires a 48 turn time, that is ridiculous. The fast and cheap appraiser is certainly not giving the customer what they paid for. The AMC is pocketing all that money for forwarding and tracking the appraisal order. Where is the value to the homeowner? The value is only provided to the lender so make them pay for it, not the homeowner or the appraiser!m2:

 

[Meandering]

Considering everyone knows the fee did include AMC charges and the very loud cries of "AMCs are ripping appraisers/consumers off" how in the world can you justify C&R is $550?

I don't need to justify anything. $550 is what the borrowers have been paying/charged and paid, for appraisal services. C&R was a combined fee under Federal definition, not my definition. On the day of the signing of the bill, we were supposed to get the entire nut, that's the LAW the president signed. and between that day and any day they change the federal policy that borrowers can pay more than the customary and reasonable appraisal fee, appraisers are owed the full nut, no matter what they accepted because that is the LAW as written.

Are you going to back track and say $550+ wasn't a rip off?

Nope, I'm saying that the government warrantied to the Amercian Public that what it was being charged and paid for Appraisal services was no more than the Customary & Reasonable Fee, and if the public was overcharged more than the Customary and Reasonable Appraisal Fees, well there are some borrowers that are owned money as a refund. Take a look, they know it, you just need to realize that since 2003 banks have been refunding overcharged closing fees to borrowers, but now not just the borrowers, they owe the appraisers to. if the C&R is $350, and they charged the borrower $550 and paid the appraiser $200, well they owe $150 to the appraiser and $200 to the borrower as trebile damages, cause this is real estate.

Bank of America To Pay $108 Million To Borrowers
http://www.allmandandlee.com/bankru...k-of-america-to-pay-108-million-to-borrowers/


And FWIW what HUD says and what HUD enforces usually don't match.

True, but because it was not enforced does not mean it is unenforceable, and no where does it say that only HUD gets to enforce it.


Don't get greedy.
Not me, just honest about what is.

AMC appraisers should be happy with anything over what they're getting now.

Spoken like a true slave. Stand up for your god given rights as Amercians to work for what you get and to seek better, instead of clammering for the scraps from the tables of the AMCs.

As for the rest of the appraisal profession we'll have to deal with the unexpected consequences of this mess of a law while the AMCers will be happy just popping out forms all day.

As part of "the rest of the appraisal profession" I agree with you, we need to come down to the reality of Residential Appraisers because like cancer and mold, leeches multiply and there already are forms for commercial work. Do not think that it is off their adgenda to attack all of the industry.

Wait until divorce judges decide that appraisers should be chosen from AMCs because advocacy is not allowed in appraising for market value, and then include that with tax appeals.

Check your ego and look at the entire forest, not just your own tree.


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[Non Sequitur]

Spoken like a true slave. Stand up for your god given rights as Amercians to work for what you get and to seek better, instead of clammering for the scraps from the tables of the AMCs.

Get a life Marion. You don't know me or my background but somehow you feel that flippant remark is appropriate.

I don't need a federal law, I work for a living and charge for it. Grow some character and try it.

Check your ego and look at the entire forest, not just your own tree.

I did. The industry got screwed by you and other supporters of HR 4173, thanks for a job well done. You pulled a fast one and continue to do so by pounding on customary and reasonable and refusing to address the other 99.99% that deals with appraiser/appraisal issues. Sad thing is, all of the screaming and hollering in the world isn't going to stop ding-dongs from working for $175 a pop or lenders paying them $175 a pop.

 

[KenAZ]

Get a life Marion. You don't know me or my background but somehow you feel that flippant remark is appropriate.

I don't need a federal law, I work for a living and charge for it. Grow some character and try it.

It is amazing that the bill that has been needed for many decades has finally been passed, and yet there is whining still from a select few.

Read the bill. You will find that most of your concerns are unfounded. No one (Including AMC's) has found a loophole regarding C&R yet. YOU are LUCKY that this bill passed. This helped you. Now YOU can continue to work hard and charge for it, because as things were heading, you were soon doomed to work hard and get nothing for it.

What was slowly happening is that those of you with the magical honest high paying clients were losing them little by little. They were either joining AMC's or another appraiser was discovering this client and low balling you.

ALERT

Sometimes you don't know that you lost a client to a skippy, because the client will tell you that they are slow instead of breaking the news to you that your high standards and great client relations has been destroyed by a lower bidder.

This was happening. It was even happening to appraisers like you who said that it could not happen to you. When we actually attend the education credit classes instead of taking them online, we talk to one another. Every real appraiser I have found or talked to in these classes(Not from the internet) has had a client stolen from them due to lower fees, or lost a client to an AMC.

It is only in this forum that we have these mystical appraisers that have these magical clients that will always pay full fee and would never dump them for a skippy. You will notice that these appraisers NEVER tell us who these clients are (Including you!!)

Why ??

Because

A) They are afraid someone will steal the client
B) The client does not exist
C) They are an AMC troll
(Shocking, but people have been known to lie on the internet)

What we need to be paid, is what we deseerve as an appraiser. We are not wheeler dealers, we are not friends of the clients, we are not allowed to have "sides" (see USPAP), and fortunately now we are not allowed to undercut other appraisers or be undercut by clients. We can concentrate on appraisals instead of competing for clients through fee reduction.