I'm not surprised..

[Zoe]

Focus Sir George on separation of fees on separation of fees on truth in lending disclosures.

 

[J Grant]

Okay, so the borrower gets billed only for the appraisal.

Have you thought this through at all? Do you actually think that's going to stop an AMC from shopping by fee?

Do you have a blind spot on the subject?

The borrower gets billed for the appraisal $500.. The lender pays the appraisers the $500 that the borrower paid

The lender pays the AMC 100 per order ( or whatever they negotiate between them) .

Then WHY would an AMC shop appraiser by fee in this scenario? The AMC can not keep a dime of the appraiser's fee in this paradigm.

 

[Zoe]

I don't think anybody has a problem with that. But in reality it would accomplish nothing when it comes to appraisal fees

Your not reading my posts. I understand competition.

 

[J Grant]

I said 100x that I'm all for it. More Transparency > Less Transparency. I also advocate for approaching the feds to reconsider and revise their interpretation of C&R to revert to its original meaning and intent. I greatly prefer the prospect of appraisal fees floating at market rate. Even if it ends up floating at market rate in real time on a day-to-day basis. Maybe it's $450 today but $500 next Thursday.

No profession "floats fees" weekly.

The lenders do not want to waste time each week to check a fee difference, have to adjust it for all their customers etc.

Right now, the system works very well. A yearly fee survey is done for C and R and that fee is set for the year in a region for the lenders; panel for regular non complex work

 

[Zoe]

Separation of fees on truth in lending disclosures would create intense competition between amccccss. Understand?

 

[Dublin ohio]

Do you have a blind spot on the subject?

The borrower gets billed for the appraisal $500.. The lender pays the appraisers the $500 that the borrower paid

The lender pays the AMC 100 per order ( or whatever they negotiate between them) .

Then WHY would an AMC shop appraiser by fee in this scenario? The AMC can not keep a dime of the appraiser's fee in this paradigm.

If the lenders cared there is nothing I know of that prevents them from setting the floor now. I know of clients using AMCs that do just that. It wouldn't take an act of Congress or even the CFPB to step in. The lenders could do that on their own if they cared

 

[Dublin ohio]

Separation of fees on truth in lending disclosures would create intense competition between amccccss. Understand?

So you think the borrower would shop AMC fees?

 

[Zoe]

IMHO, probably deathly competition if fees were separated on truth in lending disclosures.

 

[George Hatch]

Do you have a blind spot on the subject?

The borrower gets billed for the appraisal $500.. The lender pays the appraisers the $500 that the borrower paid

The lender pays the AMC 100 per order ( or whatever they negotiate between them) .

Then WHY would an AMC shop appraiser by fee in this scenario? The AMC can not keep a dime of the appraiser's fee in this paradigm.

The borrower could just as easily get billed for $300 if the AMC can find an appraiser to do it for that much.

Try thinking like a lender on this:

AMC#1 can deliver appraisals at $300-to-the-borrower​

or​

AMC#2 can deliver appraisals at $350-to-the-borrower​

As a lender you know that these AMCs are pitching these same proposals to all your competitors, so you know that if you won't take the low cost leader your competition will, and they might end up doing more deals than you as a result of it. What is the most logical decision you can make under those conditions?

 

[Dublin ohio]

IMHO, probably deathly competition if fees were separated on truth in lending disclosures.

and who or what will drive that competition.