FANNIE bonds with AMCs, over your dead low paid body.

[Zoe]

I won't swear FNMA or Freddie could not have an impact but Danny is not CEO of either.

 

[Dublin ohio]

If I'm not mistaken, the disclosure of cost breakdown comes AFTER they're sucked in and have no choice in fee variation nor purveyor. Too late then

The trid is before the appraisal is ordered. So if disclosure was required it would show up on the trid

 

[Sandra Koutsopoulos]

For quite a few years my state has required that my fee be disclosed within the report. So they know what I was paid and they know what they paid. I guess the borrowers are either too stupid to compare the differences or dgaf

As you say, in some states the breakdown of fee is disclosed WITHIN THE REPORT. That is, after the report is ordered and received. NOT at a point where consumer can have any say-so re: AMC fee vs appraiser fee. Too late then.

 

[DWiley]

And what about my question on CE and instructor fees? As a student, do you care what the instructor makes, or are you content to just know the course price?

I know you won't answer this, and we all know why you won't. When you look at the fees you pay for CE over a renewal cycle, the total is probably comparable to what a consumer pays for an appraisal. and you have to do that every time you renew, while consumers only have to pay for appraisals when they get new loans. If what you assert about consumers and fees is correct, why have I never seen one thread here about the concern for instructor fees?

I would wager that you have never in your life asked a school what they were paying the instructor or expressed concern that the appraiser instructor was getting a fair wage. We all just assume that the fee paid to the instructor is acceptable or the instructor would not be teaching the class.

 

[Dublin ohio]

As you say, in some states the breakdown of fee is disclosed WITHIN THE REPORT. That is, after the report is ordered and received. NOT at a point where consumer can have any say-so re: AMC fee vs appraiser fee. Too late then.

Regardless what would be the borrowers recourse if it was disclosed up front

 

[J Grant]

Wrt fee disclosure and breakouts...there are lawsuits in progress now and perhaps more to come -

I am not a lawyer ( most of us are not ), however, I did sell RE for over 5 years and keep up with some of the legislative changes. It is not legal for RE agents to "steer" clients to use this or that home inspection company or title, and IDK if this rule applies to lenders as well. ( no time to research it today ).

Borrowers in regulated loans do not choose their appraiser. And I am NOT saying borrowers should choose the appraiser - it is a terrible idea. However, borrowers rely on the lender to choose a good and competent appraiser for them. In the case of an AMC , the lender outsources the appraiser selection for an assignment. Therefore, the borrower should be informed that the selection rests in large part in an AMC on the lowest fee or lower fee or bid of an appraiser to "win" an assignment, which can bypass more experienced and competent appraisers whose $fee is covered by what the borrower paid.

Whether a lawyer would call that appraiser selection based on a fee that most profits a third party is steering or theft of services or simply lack of full dislcosure idk, but I bet most borrowers would be very upset if they knew about HOW their appraiser was chosen when a third-party AMC is used. Which is why great pains are taken so that the borrower not know about it.

 

[Sandra Koutsopoulos]

It would just be another line item on the trid or closing statement. Honest question: What would be the borrowers recourse if they did throw a fit

EXACTLY! Why shouldn't consumers have the right to shop around for what those line items really are?
In fact, I'm doing a closing statement on my listing, and got down to title/escrow fees. Turns out 5 title companies give 25% discount to senior O/O sellers! My seller is very strapped for cash & will have to bring money to closing. So instead of using my initial contact for title, I'm going with the one which will save him $500 and is also of similar quality as my initial choice. Making financial choices with good info in advance gives consumers some power over their $$$$, and it's also competitive.

 

[J Grant]

As you say, in some states the breakdown of fee is disclosed WITHIN THE REPORT. That is, after the report is ordered and received. NOT at a point where consumer can have any say-so re: AMC fee vs appraiser fee. Too late then.

Exactly- when the fee is broken out in the appraisal report, it is a done deal and too late for the borrower to object to, and many might not even read that far into a report at that point- vs having it bold type, disclosed up front when they apply for a loan.
'
The dirty secret is that when the borrower applies for the loan, they KNOW what the appraisal fee is ( $600 for example ). But the dirty secret is that when the borrower applies for the loan, they do not know what split of their $600 is kept by an AMC ( or even if an AMC is being used )

The fun part is that it would be impossible for the lender to break out the fee to the borrower at application unless the AMC was on a cost-plus basis ( AMC keeps the same $150 regardless of which appraiser is chosen. But in the current system, where most AMCs are not on cost plus, they hold flea market style bids or search for low fees, so the lender does not know what the appraiser /AMC fee breakout will be, so they can not disclose it up front.

It is the opposite of a public trust mission and the transparency they allude to..

 

[Dublin ohio]

EXACTLY! Why shouldn't consumers have the right to shop around for what those line items really are?

So you are proposing that the lender allow the borrower to shop AMCs and/or appraisers? I know what some of the AMCs charge and it is less than what the pay me. So which fee will catch the borrowers eye

 

[J Grant]

I know you won't answer this, and we all know why you won't. When you look at the fees you pay for CE over a renewal cycle, the total is probably comparable to what a consumer pays for an appraisal. and you have to do that every time you renew, while consumers only have to pay for appraisals when they get new loans. If what you assert about consumers and fees is correct, why have I never seen one thread here about the concern for instructor fees?

I would wager that you have never in your life asked a school what they were paying the instructor or expressed concern that the appraiser instructor was getting a fair wage. We all just assume that the fee paid to the instructor is acceptable or the instructor would not be teaching the class.

Again, this is an inane comparison.

I pay $500 for a renewal of CE. The instructors, I assume, get paid a flat fee of X$ for designing the internet course or teaching the in-person course. The other 1000 students and I who took this course in the state of FL ( for discussion ) WE ALL RECEIVED THE SAME COURSE for our $500, regardless of what the instructor and CE negotiated for their course.

But with an appraisal, say 1000 borrowers in a region paid the same $500 appraisal fee- the borrowers get assigned DIFFERENT appraisers and the results can be IFFERENT depednign in part on which appraiser is chosen - so it invloves assignming to possibly less geo competent and experienced appraisers based on a hidden from borrower fee split ( a low fee or bid by the appraiser )

And I would care about what they paid the instructors if the CE course was garbage and /or did not meet state approval when I apply to renew my license.