Josh Tucker, an appraisal manager at a bank in Texas, has spent the past two years gathering evidence of the fee imbalance through a nonprofit he cofounded known as the Appraisal Regulation Compliance Council, which aims to root out fraud in appraisals. His organization has collected hundreds of examples of appraisal orders from some of the largest AMCs — Class Valuation, Clear Capital, Solidifi, and Nations Valuation Services, among others — and compared them with the standard fee schedules the AMCs provide to lenders. Other internal documents show the appraiser's fee alongside the AMC's fee. In many instances the AMC's cut roughly matches or exceeds the amount paid to the appraiser. Take, for example, a single-family home in California that was up for refinancing. The appraisal was managed by Solidifi, a nationwide AMC based in Buffalo, New York, that says it handles about one in nine appraisals in the US. The appraiser's fee was listed as $375, but the AMC fee was a whopping $725, for a total cost of $1,100 to the client. In another case, a townhome in Georgia, both Solidifi's and the appraiser's fees were about $300. A Solidifi spokesperson tells me that appraisers generally receive the majority of appraisal fees, adding that the company provides fee transparency to the lender and the appraiser by disclosing the breakdown for every transaction. The spokesperson also says that the company follows all applicable state and federal regulations, including paying customary and reasonable fees to appraisers.
Tucker calls AMCs' charges "one of the fees that is absolutely price gouging the consumer." It's unclear how much AMCs rake in in total, but securities filings from Real Matters, the publicly traded parent company of Solidifi, offer an approximation. Each year the company estimates the "total addressable market" for AMC services in the US. In the five years from 2019 through 2023, lenders ordered about 28 million appraisals for purchase and refinance mortgage originations. Real Matters multiplies that volume by Solidifi's average revenue per transaction to arrive at a dollar figure estimating how much Solidifi could bring in if it captured every single one of those transactions: $16.4 billion over those five years. Take into account the estimate that AMCs manage about 75% of appraisals and assume that Solidifi's fees are in line with the rest of the industry, and it appears AMCs could have charged consumers about $12.3 billion in that period, or about $2.5 billion a year.
This is a ballpark figure, since AMC fees vary by company and their revenue depends on the
number of loans in a given year . But it may also be a conservative estimate; Real Matters says its estimate of appraisal volume is low because it doesn't include certain types of loans for which there isn't good data. Solidifi reports healthy margins on the appraisals it manages: After subtracting the payment to the appraiser and other "transaction costs," Solidifi keeps anywhere from 22% to almost 28% of the fees it charges lenders, depending on the year. And again, that fee is passed along to the borrower as part of closing costs.
Schiffman, of the AMC industry group REVAA, says that cases in which the AMC's fee outweighs the appraiser's are rare and that AMCs have their own costs to bear.
"It's more of an anomaly than anything else," Schiffman tells me. "Usually it's about the same. Sometimes it's higher, sometimes it's way lower." Chris Likens, the CEO of Nations Valuation Services, tells me his company's fees on a transaction never exceed the amount paid to the appraiser.
In some instances, both Schiffman and Likens say, an AMC may actually end up losing money on an appraisal if it turns out to be more complicated than expected. Both also note that finding an appraiser isn't the only thing AMCs do — they provide quality control after the appraisal to protect both lenders and consumers from faulty valuations. However, a 2018 working paper from the Federal Housing Finance Agency found that AMC and non-AMC appraisals "share a similar propensity for mistakes" and concluded there was "no clear evidence of any systematic quality differences between appraisals associated and unassociated with AMCs."
One solution, at least, seems pretty simple: Require lenders to make AMCs' fees clear to consumers. Have a line in the closing paperwork that shows what the AMC is making and another that shows what the appraiser billed. The website of one nationwide AMC advises mortgage lenders to check how their AMC's fees compare to the average, suggesting that "your AMC should retain about $100 to $125 per appraisal" with the remainder going to the appraiser. Yet the Appraisal Regulation Compliance Council has collected hundreds of examples in which the AMC's cut well surpassed that figure. And if lenders benefit from knowing the exact split, it seems reasonable for the consumer — the person actually paying for all this — to also have the chance to decide whether they're getting a fair shake.
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