I think I'm with tlark on this issue. When I spoke to a direct lender I do work for, one of their ppl told me they were taking 'classes' on how to READ the 3.6 reports! So it sounds like it doesn't stand on its own legs as a logical functioning program. ...and if the appraiser doesn't do the report 'correctly', how much MORE difficult a time will lenders have to make heads or tails of the flawed report?
An annoying current aspect is that AMCs and lenders are jumping the gun to inquire if we're '3.6 certified' yet?! WTH! They also want me/us to give them our fee/rate for various reports NOW for when the 3.6 is in effect. And how the heck can we knowledgably quote a fee for that which is not readily available and for which we have zero experience because it is still basically in Beta-testing? If it is as big a bugger as folks here have described who have taken a whack at it, then it isn't realistic to do reports for the 'old' fees. If it requires carrying around an ipad to do photos, measurements etc, and if there is not an alternative work-around for that, then simply requiring new expensive appraiser equipment hits our bottom line. Since when does your LICENSE and your ability to provide credible appraisals require buying certain equipment for lender's mandated form? If lenders require all that including the additional technology, there must be a cost to them for requiring that.
Right now, with ppl losing their houses, my appraisal work level has increased for pre-foreclosures and REOs, so that's good for me. But at some point the economy will recover, and when it does, if the 3.6 is required, I predict that there will be a 3-6 months chaos period of accepted offers where loans are delayed because there is a shortage of trained, knowledgeable appraisers to provide appraisal reports for dead cheap fees. Even if they broadly raise the appraisal fees, there will be a learning curve as well as a 'throw-in-the-towel' percentage, where we appraisers say enough is enough already, and either retire or change how we earn money. When it comes down to net profit looking like minimum wage or less, then our 'profession' becomes a licensed, highly regulated hobby where we are supporting other services, like databases, MLS, software, E&O, licensing & CE fees, and other costs like wear & tear on the vehicle, gas, computers and printers, cellphones, websites...
Being in business isn't free, but most AMCs treat us like we have no operating costs, and our time is worth $0; all they want is the report, and the report is what they are negotiating price on. So I guess being able to push a button for a value will be the way it is, and we shall see what the consequences will be. Will there be more bad loans made that hurt lenders/investors? Without appraisers' 'eyes-on' the property, reality may not become apparent until the property forecloses and agents try to sell it again. Meanwhile, if lenders are badly hurt, they will get bailouts of our tax dollars again, as usual. And then there will be a new system of some sort.