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I'm not surprised..

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.
Why hasn't the VA been sued or been put out of business? Also...coincidence that most of the AMCs on the list are the ones that the GSEs require lenders to use for certain products.

As for the OP, someone needs to send that to the attorneys that sued the Realtors.

Also send it to many of the non-profit orgs that are currently investigating the appraisal profession.

If the borrower could shop for the lowest fee, no problem. They cant. I have a current settlement statement in front of me....Appraisal fee $600. Nothing about an AMC fee? Why are AMCs getting away with fruad or legal theft?

Maybe they can start a class action lawsuit on behalf of the borrowers.

Furthermore, tell the attorneys that the GSEs require the use of +-5 AMCs for some of their products which...restrictive trade practices
 
What AMCs, lenders and supporters of this wicked system deserve.

View attachment 90776
That one hurts my feelings. I have told this story before. My next door neighbor was gunner in the bottom of an airplane in world war 2. The Germans shot them down. They were captured and he was prisoner of war for 16 months. The govt sent his wife a letter saying he was gone. His wife got a letter from him like 6 months later and ....

She framed the letter from him.

She had to call govt to tell them he was alive.

He got home.. He told me stories of how some tried to escape and they would send the dogs and bring them right back and make them kneel down in front of prisoners and shoot them in back of head.

Do you understand now prisoners?
 
CFPB probably has more power than any regulatory body in the lending world. That is why Chopra always spoke last in appraisal bias hearings.
 
Furthermore, tell the attorneys that the GSEs require the use of +-5 AMCs for some of their products which...restrictive trade practices
You sure that is an accurate claim? :) I count just a few more than 5.

 
AMC's and lenders are only doing what they've been authorized to do - and they, just like anyone else, will push the envelope of legality in order to make more $. As long as what they're doing is legal though - as immoral as it may be - they're still legally free to do so. The ones you should be blaming are the ones who made the current model legal - or, at least, failed to make it illegal. And, at the end of the day, what is there to outlaw? You'd outlaw Appraiser X choosing to bid low so that they get more work than Appraiser Y? How do you outlaw that?

I see where you’re coming from, but I have to disagree on a few points. Sure, AMC's and lenders are working within the "legal" boundaries and are driven by profit, but that doesn’t mean we should let them off the hook. Even if their actions are legal, they can still lead to major issues like inflated property values, predatory lending, and shoddy appraisals. Just because something’s legal doesn’t mean it’s ethical or beneficial for everyone. Laws often don’t keep up with how things actually work, and as St. Augustine said, "Nam mihi lex esse non videtur, quae justa non fuerit" — "A law that is not just is no law at all." So while we can criticize the lawmakers and regulators for the system they’ve created, we also need to address how those operating within it impact fairness and transparency. The current system is deeply flawed, rewarding the worst practices and pushing out the competent and ethical professionals. Plus, consumers are paying much more than they should. We need better regulations to fix these problems and make the process fairer for everyone.
 
Why hasn't the VA been sued or been put out of business? Also...coincidence that most of the AMCs on the list are the ones that the GSEs require lenders to use for certain products.

As for the OP, someone needs to send that to the attorneys that sued the Realtors.

Also send it to many of the non-profit orgs that are currently investigating the appraisal profession.

If the borrower could shop for the lowest fee, no problem. They cant. I have a current settlement statement in front of me....Appraisal fee $600. Nothing about an AMC fee? Why are AMCs getting away with fruad or legal theft?

Maybe they can start a class action lawsuit on behalf of the borrowers.

Furthermore, tell the attorneys that the GSEs require the use of +-5 AMCs for some of their products which...restrictive trade practices
Danny can't delve into that.

I know why VA is not in picture of appraisal bias is because they will fire an appraiser in a minute if the suspect. Many reasons they would fire an appraiser. Plus they needed no bailout.

The borrower can't shop. They are not client.

Separation of fees between APPRAISER and AMC would have totally changed the landscape of appraisal profession.

Lawsuit no without a union

CFPB is the key on disclosure if separation of fees between AMC and APPRAISER on truth in lending disclosures. Trust me it would have far reaching implications.
 
Just look at fines CFPB has imposed recently. Just google CFPB and look at recent fines they have put on various entities.
 
if it possible the AMCs are more useless then TAF...
 
when crooked coumo and fannie slithered into some dingy pale room to create the unconstitutional hvcc...it was over for independent appraisers and public trust
 
if it possible the AMCs are more useless then TAF...

Both share a common trait: they both extract money from the appraiser while delivering minimal value in return.
 
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