Hybrid

[Terrel L. Shields]

appraiser is getting 100% of the fee that he or she agreed to.

Never mind the appraiser was pressured to accept a low fee or if bidding higher, the assignment might be jerked out from under them tomorrow if they find another appraiser who will do it for less. The IAG goes into some detail about banks using "third party" appraisal firms (AMCs) and how quality not price should determine the choice in appraisers. Clearly neither AMCs nor bid systems do anything but pit appraiser against appraiser in a bidding war and quality of work never enters the equation. It is 100% about turn time and fee.

 

[DWiley]

Clearly neither AMCs nor bid systems do anything but pit appraiser against appraiser in a bidding war and quality of work never enters the equation. It is 100% about turn time and fee.

I cannot speak to the policies of others, but that is 100% not true for us The appraisers' quality scores account for 67% of the scoring process we use to rank appraisers for selection.

 

[Eli]

What if you reversed the scenario and appraisers bid an AMC’s services to lenders? See the delimma how the balance shifts on antitrust issues including fee disclosure to borrowers?

Louisiana has no money, but they will win on antitrust issues. Maybe not the complaint at hand, but they will win and capitalize on “other” antitrust issues.

Get ready. The fat lady is sucking on that lemon.

 

[Joe Flacco]

I cannot speak to the policies of others, but that is 100% not true for us The appraisers' quality scores account for 67% of the scoring process we use to rank appraisers for selection.

Yeah but AMC quality scores are a joke.

 

[Joe Flacco]

Even standard 3 reviews don't do a proper job of determining if a appraisal is good. I am sure your stupid box checking clerks are fully qualified to determine appraisal quality.

 

[Terrel L. Shields]

The appraisers' quality scores account for

...squat?

I would be curious how that "quality" is vetted. Breath on mirror? All the stips appraisers complain of, and bank/AMC complaints about "quality" and "shortage" suggests the quality bar is fairly low. But how many here has got an assignment jerked within 24 hours and assigned elsewhere at a lower fee? How many like myself refuse to bid? Refuse to accept low fees? And thus are never part of the pool of AMC appraisers. Some of those who defend the AMC model on this site do not do AMC work themselves. What is that saying?

I have any number of unsolicited emails from CoreLogic and others telling me they have a job in some remote town in my state, rarely within 50 miles of my home and the (set) fee is $285 or some such, so how did they vet me? I am not on their list. They obviously didn't know I don't even own form software. How could my qualifications be vetted anything but zero percent?

 

[Eli]

Don’t ever underestimate lawyers on antitrust issues.

 

[Joe Flacco]

It doesn't matter for him. He said he is not responsible for the quality of reports. He says he is responsible for strategy.

 

[hastalavista]

Louisiana has no money, but they will win on antitrust issues. Maybe not the complaint at hand, but they will win and capitalize on “other” antitrust issues.

(my bold)

I was wondering when and/or if you were going to hedge your bet.

However, let me offer you some information which, while not specifically helping your cause, may create a longer FTC hearing process than what exists now:
One of the decisions from SCOTUS that just came out was a case involving the SEC and their administrative law judge appointment process. Here is an article that goes into detail...

https://www.lexology.com/library/detail.aspx?g=28994663-2165-47df-abba-8abc27caca6a​

but the gist is that if the ALJs are not appointed using the proper procedure, their past rulings and current pending cases may be thrown out and a new hearing from a properly appointed ALJ may be required (if the agency wants to pursue the action).

 

[Eli]

(my bold)

I was wondering when and/or if you were going to hedge your bet.

However, let me offer you some information which, while not specifically helping your cause, may create a longer FTC hearing process than what exists now:
One of the decisions from SCOTUS that just came out was a case involving the SEC and their administrative law judge appointment process. Here is an article that goes into detail...

https://www.lexology.com/library/detail.aspx?g=28994663-2165-47df-abba-8abc27caca6a​

but the gist is that if the ALJs are not appointed using the proper procedure, their past rulings and current pending cases may be thrown out and a new hearing from a properly appointed ALJ may be required (if the agency wants to pursue the action).

Antitrust law is deep. The issues with like the dental thing don’t hold a candle to this market. Louisiana is not in a defensive position. I assure you.