I'm not surprised..

[Mejappz]

they are a hop skip and a jump away from me...i should james okeefe them

By all means do. The forum is starting to implode once again. I, am barely able to log in. Do you think this is by coincidence? I had to piggyback on Terrel's Avatar to get in.

 

[Zoe]

One point to remember always. GSE or AMC are not your client. If GSE hires you directly, then they are your client.

 

[George Hatch]

who are they to tell us not to COD...and why wouldn't you want to COD....dividers like to divide same story a different day

They are not going COD-less because they want to. If they could then they would.

 

[J Grant]

When I worked in AMCland, the great majority of lenders we worked with wanted a fixed price, or at least a fixed price per state. And, who could blame them? Under current disclosure rules, if a lender's GFE indicates the appraisal cost will be $X, and it turns out to be $50 higher, then the lender has to provide new disclosures, and no one wants to do that.

For example, suppose the agreed upon fee in a state is $650, with no change unless the appraiser fee exceeds $1,000 (a very typical arrangement). If appraiser charges $500, the AMC grosses $150. If appraiser charges $650, then the AMC grosses $0. If appraiser charges $750, then the AMC, eats $100. If appraiser charges $250, then the AMC grosses $500. All of those scenarios can and do happen.

If one wants to change how lenders approach AMC fees, then the key change would be to allow changes in appraisal fees without re-disclosure. Unless or until that happens, the fixed-total-price model will be the one that most lenders will seek.

Whether the AMC makes money or loses money on an order (most of the time they make money) but it is not what concerns the appariser. What we should stress is why the lenders and banks have the incentive to use the AMCis (-regardless of what $ amount the lender and AMC agree on as a "fee,") the bank/lender typically DOES NOT PAY A HARD COST to the AMC the majority of the time, correct?

For example, an AMC makes $250 from an appraisal order where the agreed fee between the AMC and lender is $550, The AMC shops the order , gets an appraiser for $300, and AMC keeps $250 - - it cost the lender nothing as a hard cost for that to happen.

Does anyone believe that if the lender had to pay the $250 as a hard cost to the AMC, that the lender would continue to use the AMC ? The lender would drop them like a hot potato and go back to using their own fee panel because, per order, it would be cheaper.

 

[chad hampton]

If a system is in place where an AMC or an appraiser has to lose money due to regulation, then something needs to be changed with the regulation. But borrowers will tell you that appraisal fees have never been higher and appraisers have never been played less- With the exception of a few years in the early 2010s AMC were given 80% of the market.

if Appraisal fees are forced to be listed on the GFE, then AMC fees should be capped at 20% of whatever that fee is. And then we’re all in this together.

 

[alebrewer]

Does anyone believe that if the lender had to pay the $250 as a hard cost to the AMC, that the lender would continue to use the AMC ? The lender would drop them like a hot potato and go back to using their own fee panel because, per order, it would be cheaper.

The lender still wouldn't have to pay it, J. The borrower would still pay the 'total' appraisal fee - even if it's broken out as 'Appraisal Fee' and 'Appraisal Admin Fee'.

 

[NC Appraising]

Feelings nothing but feelings.

View attachment 90779

Send that to the law firm also. Let the lawyers sue them of behalf of the borrowers in a class action lawsuit suit.

Appraisers are playing checkers and the AMCs are playing chess.

1. Nobody likes appraisers.
2. Agents, brokers, bankers, loan officers all want us gone.
3. We have no one to back us.

This is why we have to stay out of it.

We have to make the borrower the victim. If enough groups can lobby or raise cane to the right people about how the borrowers are being overcharged, maybe things will change and we could benefit from it...

How? If the AMCs and lenders get sued or the powers that be steps in and makes the necessary changes, it will force, hopefully:

1. Some AMCs to shut their doors.
2. Make the payout more transparent. A Cost plus system. It would force the lender to pay a set fee to the AMC on a per order basis. This would reduce the need for the AMC to find the cheapest appraiser just to increase the profits of said AMC. This could benifit appraisers.

AMCs should be competing with others AMCs for business....if true market competition is at play, how can an AMC make so much money on an order? Or is it becuse a few AMCs dominate the market? Or is it because lenders only use one or two AMCs.

 

[George Hatch]

So, in other words, the Dodd-Frank Act coupled with GSE guidelines, indirectly inject AMCs into the process of assigning and paying appraisers. And they do this without any control of the process of compensating appraisers other than the so-called "reasonable fee" requirement - that can be manipulated downward over time. We know what AMCs do, many appraisers have worked directly for them. It has also long since been the case that residential appraisers can barely make a living with such a setup. So, it is time to get rid of them. You can replace all AMCs with the GSEs - and we would have a better situation. So, the lenders go to the GSEs for the appraisal, the GSE hires the appraiser, and IT deals with the end-result.

My understanding of it is that the GSEs were established to act solely as a secondary market conduit, not as an alternative for loan origination or to compete with the originating lenders. To either accept or reject the loan package, not participate in it's development. I don't think they're even allowed to engage appraisals for loan origination.

 

[Mejappz]

if Appraisal fees are forced to be listed on the GFE, then AMC fees should be capped at 20% of whatever that fee is. And then we’re all in this together.

Surprise, surprise look who doesn't want the fee to be disclosed?

 

[NC Appraising]

Surprise, surprise look who doesn't want the fee to be disclosed?

View attachment 90792

AMCs should be competing with others AMCs for business...

Assuming the OP letter is accurate,

If true market competition is at play between the AMCs, how can an AMC make so much money on an order?

Something does not add up.