Customary and reasonable fees - 90 days

[Caligirl]

Re "reasonable and customary fees" please take 10 minutes and complete the survey at www.feesurvey.com.

Whatever the AMC is charging the consumer for an appraisal seems like the reasonable and customary fee which should be paid to the appraiser. Why do you need a survey? Why don't you survey what the AMCs are charging consumers, isn't that a reasonable and customary appraisal fee?

 

[NC Appraising]

Joan,


Thanks for the survey.

I have not filled it out yet because it asks for personal information. Will any of the AMCs or banks see this personal information? I'm concerned with getting "blacklisted".

I thank more appraisers would fill it out if we could be certain that it would not be held against us.



Appraisers do not make this difficult. Just fill it out if you want to, and if you do not like it, make your own.




Thanks again for the survey.

 

[NC Appraising]

Whatever the AMC is charging the consumer for an appraisal seems like the reasonable and customary fee which should be paid to the appraiser. Why do you need a survey? Why don't you survey what the AMCs are charging consumers, isn't that a reasonable and customary appraisal fee?

Because that fee includes the appraisers portion, and the HUGE profit that the AMC makes.


As other "threads" have stated, and the Alamode survey, typical fees are $290-$375.

HUD 1's and borrowers are reporting a "charge" of $350-$550.


So lets not get greedy....






ALTHOUGH.......If they want to use the "Before HVCC" fees from the HUD 1s, I think that would be acceptable. That would make the most sense.

 

[Caligirl]

Because that fee includes the appraisers portion, and the HUGE profit that the AMC makes.

Those should be two different charges, not one 'appraisal' charge to the consumer. Are consumers aware of the two fees?

 

[NC Appraising]

Heck no. But since most borrowers only deal with a mortgage transaction every 8 years to once in their lifetime, and most are clueless on the process, the AMC's and banks can get away with it. They have no idea that a newbie thats out of the area, or a "volume" appraiser that has to do 2 a day and just pulls three comps and moves on is appraising their property.


Sign here, that all they know.

 

[BigBear Seattle]

The enforcement system will not be in operation for 90 days after the president signed Dodd-Frank, but there is no reason for us to wait to start insisting on 'reasonable and customary' fees. I don't have access to the HUD-1's for the past year, but the lenders know what they have be charging the borrower for an appraisal -- and it is NOT what the AMC's they use have been paying us.
The VA fee for a Fannie 1004 with 1004-MC in Western Washington is $500. The ala mode survey for the three counties I cover ranged from $420 to $450.
I cited this data to an AMC today and told them if they increased the fee to $460 from the $300 they offered, I would accept the assignment. Still waiting for their response, but I have 5 jobs open right now.

 

[BigBear Seattle]

ALTHOUGH.......If they want to use the "Before HVCC" fees from the HUD 1s, I think that would be acceptable. That would make the most sense.

What makes you think the fee shown on the HUD-1 changed because of the HVCC?
Lenders charge the borrower for the various 'third-party' fees -- appraisal, title and credit report, and they show the amounts charged for each service on the HUD-1. They collect $450-$600 here in the Seattle area and that is what shows on the HUD-1 -- it is what they collected for an appraisal before HVCC and are still collecting. Before HVCC, they could show the statement from the appraiser, now they show the invoice from the AMC. What they do not show is the invoice from the appraiser to the AMC.

 

[NC Appraising]

Maybe you mis-interpreted my post. Prior HVCC AMCs controlled 30-40% of the market share. Now they control 80% of the market. That is why I say, and after speaking with 20+ closing attorneys in my area are telling me that the "appraisal fee" on the HUD1 has risen post HVCC.

Appraisal fees on the line 804 HUD 1 prior to the HVCC had a typical range of $290-$350.

Appraisal fees on the line 804 HUD 1 post HVCC had a typical range of $350-$550.

Hence, the "borrower" is having to pay for the AMCs "profit" and the lenders choice for using the AMC. The AMCs have to employ another work force and make a profit. Before the HVCC and the AMCs, the lenders already had a loan processor that ordered the appraisal, credit check, title report, etc. Why should the borrower have to pay for this?

The borrower is paying more for the appraisal due to the HVCC and the AMC.


Lenders just can't say, well give me $600, and maybe 50 will go the credit report, 300 will go to the appraisal fee, and maybe the rest will go to the AMC...


Line 804: Appraisal fee



Lines 804-808 may be used to record each of the ``Required services
that we select.'' Each settlement service provider must be identified by
name and the amount paid recorded either inside the columns or as paid
to the provider outside closing (``P.O.C.''), as described in the
General Instructions.
Line 804 is used to record the appraisal fee.
Line 805 is used to record the fee for all credit reports.
Line 806 is used to record the fee for any tax service.
Line 807 is used to record any flood certification fee.
Lines 808 and additional sequentially numbered lines, as needed, are
used to record other third party services required by the loan
originator. These Lines may also be used to record other required
disclosures from the loan originator. Any such disclosures must be
listed outside the columns.

 

[BigBear Seattle]

I have not seen a high volume of HUD-1's, but here in the Seattle area, lenders have been collecting $450 to $600 for the appraisal for several years. I mentioned the other 'third party' fees, but the $450-$600 I cited was just the appraisal fee - line 804. Our base fee for a 1004 in 1990, when FIRREA took effect, was $350. By 1995, the typical fee in the area was $400 and now it is $450-$500. (Subdivision home or condo, higher for waterfront, homes on acreage, or other complex assignments.)

Pre-HVCC, the community banks and mortgage brokers were collecting that appraisal fee from the borrower and paying it to the appraiser. The major banks were collecting the same fee and paying it to their in-house or contracted AMC. Now the mortgage brokers have to route their appraisal request through their intended funding lender which normally goes through an AMC to the appraiser. Most of my mortgage appraisals are for small banks that order directly and pay my 'reasonable & customary' fee, but most of my work is for attorneys.

From what I have been told by mortgage brokers, they are paying the same fees for appraisals, but it is taking longer to get the reports and they have no knowledge of who is doing the assignment until they get the report.

I know a few appraisers who have been working primarily for AMC's and they have been getting $200 to $375. Their explanation was that if they worked for a big company like I do, they would only get 50% of the fee they billed. But they were also working for mortgage brokers and getting the "full" fee.
Now they are screaming the loudest about HVCC because they do not have the mortgage broker work that was paying for their MLS membership, computers and software, vehicle expenses, and other business operating costs.

 

[Caligirl]

lenders have been collecting $450 to $600 for the appraisal for several years. I mentioned the other 'third party' fees, but the $450-$600 I cited was just the appraisal fee - line 804.

This is exactly what I meant when I described the 'customary and reasonable fee' that *consumers* are paying for appraisals.