- Joined
- Jan 15, 2002
- Professional Status
- Certified General Appraiser
- State
- California
Regardless of whether or not an AMC is involved in a mortgage transaction the lender is still charging the borrower for the procurement, review and management of appraisers. Those services never get performed for free. How they're allocated or labeled will vary, but not the effect. In the case of the "appraisal fee" nomenclature, if a different term such as "appraisal package" or "valuation services" were used to encompass everything related to the appraisal the effects of who pays and who gets what would remain the same. All that changed was the label.
I'd like to see the disclosures broken out separately, if for no other reason than to settle the controversy of whether it makes a difference to most borrowers or not.
But once again, this complaint speaks directly to the decisions being made at the lender level, not at the AMC level. The lenders have the freedom to make the separate disclosures but many have chosen not to. So why that gets blamed on the AMCs makes no sense.
I'd like to see the disclosures broken out separately, if for no other reason than to settle the controversy of whether it makes a difference to most borrowers or not.
But once again, this complaint speaks directly to the decisions being made at the lender level, not at the AMC level. The lenders have the freedom to make the separate disclosures but many have chosen not to. So why that gets blamed on the AMCs makes no sense.