I'm not surprised..

[Joe Flacco]

There is no overhaul that is going to prevent Appraiser#A from actively seeking to underbid Appraiser#B if/when their only other alternative is to not work at all that day.

What people are saying is that collecting bids and assigning to the low bidder is a AMC thing. That is not how it works outside of AMC.

 

[Zoe]

Feed the Tiger:

Consumer Financial Protection Bureau

The CFPB's vision is a consumer finance marketplace that works for American consumers, responsible providers, and the economy as a whole.

www.consumerfinance.gov

 

[George Hatch]

What people are saying is that collecting bids and assigning to the low bidder is a AMC thing. That is not how it works outside of AMC.

I wouldn't say never on that. When I appraise SFRs for the regulated lenders they always ask for a bid. But sure, if a company's sole business is to engage and manage appraisals then that function isn't some tertiary function for them. It's literally the primary function in which they have specialized, so it would be inevitable for them to look to control costs as much as possible.

 

[Zoe]

CFPB will welcome your comments related to consumers. Trust me.

FTC would too.

There is difference in what they focus on and very professional, but they both would welcome comments from professionals.

Easy email.

They both have authority over any lender in USA.

Yes, they have authority over GSE.

 

[djd09]

THE LAW
TITLE XIV—MORTGAGE REFORM AND ANTI-PREDATORY LENDING ACT
Sec. 1400. Short title; designation as enumerated consumer law.
Subtitle F—Appraisal Activities
SEC. 1471. PROPERTY APPRAISAL REQUIREMENTS.
Chapter 2 of the Truth in Lending Act (15 U.S.C. 1631 et seq.) is amended by inserting after 129G (as added by section 1464(b)) the following new section:
SEC. 1472. APPRAISAL INDEPENDENCE REQUIREMENTS. (a) IN GENERAL.—Chapter 2 of the Truth in Lending Act (15 U.S.C. 1631 et seq.) is amended by inserting after section 129D (as added by section 1461(a)) the following new section:
‘‘§ 129E. Appraisal independence requirements

‘‘(2) INTERIM FINAL REGULATIONS.—‘‘(i) CUSTOMARY AND REASONABLE FEE.— ‘‘(1) IN GENERAL.—Lenders and their agents shall compensate fee appraisers at a rate that is customary and reasonable for appraisal services performed in the market area of the property being appraised.

Evidence for such fees may be established by objective third-party information, such as government agency fee schedules, academic studies, and independent private sector surveys. Fee studies shall exclude assignments ordered by known appraisal management companies.

 

[J Grant]

There is no overhaul that is going to prevent Appraiser#A from actively seeking to underbid Appraiser#B if/when their only other alternative is to not work at all that day.

Appraisers should not have to bid against each other for regular noncomplex res orders, and appraisers do not have to bid against each other for those same orders when ordered directly from a lender. Only the AMC;s create that bid against each other nightmare -

 

[Mejappz]

What people are saying is that collecting bids and assigning to the low bidder is a AMC thing. That is not how it works outside of AMC.

Some direct lenders work with RIMS and have incompetent bank clerks managing bid orders. These clerks often blast out bid requests and then select the cheapest option, allowing the bank to pocket the difference. I caught one bank doing this last year. However, you’re correct that, for the most part, the issue primarily lies with AMCs.

 

[J Grant]

I wouldn't say never on that. When I appraise SFRs for the regulated lenders they always ask for a bid.

I thought you do not do Fannie/freddie SFR for lenders??

That is what we are talking about, not the kind of SFR you do, which sounds like some other type of work.

 

[George Hatch]

A large percentage of the SFRs I appraise are for FRTs and other portfolio lenders. By lenders who maintain an actual panel and who hold their loans in their portfolio. I have never gotten away from appraising SFRs. I just don't specialize in GSE work like you do.

 

[J Grant]

There is no overhaul that is going to prevent Appraiser#A from actively seeking to underbid Appraiser#B if/when their only other alternative is to not work at all that day.

There is an overhaul - get rid of the AMC fee split model, which creates the AMC incentive to seek low bids ( because the lower the appraiser fee, the greater the AMC profit is)

Appraisers do not have to bid against each other for direct lender orders and they do not bid against each other for VA orders - VA and lenders pay a set fee ( tupicalluy_ that is C and R in a region, the same fee to all their panel for regular work- the direct lender only asks for a fee/bid on complex high-value orders.

Direct lenders can not fee split with themselves so they have no incentive for competitive bidding for a regular order They have a set rate they charge borrowers in a region . The third-party ( an AMC ) can split the fee, thus their incentive.