Customary and reasonable fees - 90 days

[Ken B]

I agree with the statement and the principle, however who is the supplier?
Is it the lender who is supplying the appraisal order/ job request or the appraiser who is supplying the appraisal?

I understand which way it is supposed to be, however my belief is the market for Mortgage appraisals is controlled by the lender who is supplying the job order not the appraiser who is supplying the appraisal and has been for a number of years.

Is that like asking if it is gas stations that fix price or car drivers who seek the cheapest gas in the neighborhood that fix price?

The job order/engagement letter is an agreement between a client and an appraiser for the appraiser to provide a service in exchange for compensation paid by the client. The client is on the demand side and the appraiser is on the supply side. No amount of twisted logic or "yeah, but if" can change that relationship.

 

[Karl]

You can talk & post all you want, The job will go to the lowest bidder!!

 

[Metamorphic]

Price fixing is performed on the supply side. The demand side can set acceptable prices paid all day long, but they can't fix a price.

I think price fixing is done by whomever is sufficiently organized to pull it off. If lenders decided tomorrow, "we're not going to pay more than $200 for any appraisal every, we dont care how many deals we scuttle". Pretty soon they'd have the vast majority of their appraisals being done at $200.

Likewise, if every appraiser in the country said "no less than $500 ever". They'd be paying $500.

Employees can strike. Employers can lockout. There's always a counter move. Its all about the ability to pull it off.

It just so happens that in this case we're screwed because somewhere there's about 3 guys who all have one another's phone numbers who control a sufficient volume of the mortgage landing appraisals than they can effectively price fix.

 

[Kyle77]

So is there going to be a study every year? Every 5 years? Inflation anyone?

Also, am I the only one seeing turn times and quality suffering without a reasonable and customary turn time section in the bill?

I mean,... if your going to make a bunch of regulations, how can that be left out? If your going to regulate, might as well do it right.

 

[DonRico]

Joan Trice --

Are you still checking in on this thread ? If so, I noticed the Collateral Risk Network Membership has only 5 appraisers and just about every AMC under the sun. I don't see alamode or Dave Biggers on the list although ACI and Bradford are represented.

Since alamode has an unbiased repository of fees via their Mercury Network....is there a reason they are not represented in the CRN ?

What input do the appraisers in the CRN have during the Quarterly Meetings ??

The stated goal of the CRN is "Committment to Re-Engineering the Appraisal Process" how will the Appraisers be involved in this Re-Enginnering ?

 

[KenAZ]

‘‘(1) IN GENERAL.—Lenders and their agents shall compensate fee appraisers at a rate that is customary and reasonable for appraisal services performed in the market area of the property being appraised. Evidence for such fees may be established by objective third-party information, such as government agency fee schedules, academic studies, and independent private sector surveys. Fee studies shall exclude assignments ordered by known appraisal management companies.

This law is very straightforward and is not as complex as many are trying to make it.

Reasonable and Customary excludes:

AMC Fees PAID
Split fees in appraisal shops (An Appraisal Shop is technically a fee appraiser)​

Reasonable and Customary includes:

VA Fees
Fees paid to AMCs from Lenders and Clients
Fees paid to Appraisal Shops​

 

[NC Appraising]

Joan Trice --

Are you still checking in on this thread ? If so, I noticed the Collateral Risk Network Membership has only 5 appraisers and just about every AMC under the sun. I don't see alamode or Dave Biggers on the list although ACI and Bradford are represented.

Since alamode has an unbiased repository of fees via their Mercury Network....is there a reason they are not represented in the CRN ?

What input do the appraisers in the CRN have during the Quarterly Meetings ??

The stated goal of the CRN is "Committment to Re-Engineering the Appraisal Process" how will the Appraisers be involved in this Re-Enginnering ?

I think there is more than that.


http://www.collateralrisknetwork.com/PDFs/white%20paper_04_01_09-CRN.pdf


Go to the bottom....Most are Chief appraisers that may work for the AMCs, banks, and private firms. I noticed Bill Garber, does that name ring a bell? I also saw a rep from HUD. EG, he is an appraiser.

 

[Ken B]

This law is very straightforward and is not as complex as many are trying to make it.​

Reasonable and Customary excludes:​

AMC Fees PAID
Split fees in appraisal shops (An Appraisal Shop is technically a fee appraiser)​

​

​

Reasonable and Customary includes:​

VA Fees
Fees paid to AMCs from Lenders and Clients
Fees paid to Appraisal Shops​

You're no newbie...quit trying to be sensible and reasonable. For that matter, knock off the logical and informed thing also.

 

[Pittsburgh Pete]

I think theirs more than that.


http://www.collateralrisknetwork.com/PDFs/white paper_04_01_09-CRN.pdf


Go to the bottom....Most are Chief appraisers that may work for the AMCs, banks, and private firms. I noticed Bill Garber, does that name ring a bell? I also saw a rep from HUD. EG, he is an appraiser.

Bill Garber, Director of Gov't Affairs of the AI.

 

[DonRico]

I just followed Joan's link on Page 5 of this thread and I only saw 5 names under Appraisers.

Your link above to the White Paper has more names, but no affiliations. I skipped to the Summary of the 13 page White Paper and saw the phrase "Appraisers are unrepresented or worse, misrepresented" I'm concerned.

With a Mission Statement that says Re-Engineering the Appraisal Process, I ask again....

What input do the appraisers in the CRN have during the Quarterly Meetings ??