You're kidding, right?
March 31, 2018 - Bundled fees. AMCs are competing with each other on the basis of the lowest bundled fee
April, 1, 2018 - Separate fees. AMCs are competing with each other on the basis of the lowest combination of appraisal fees+AMC fees
It is STILL the combination of appraisal fees and AMC fees with separate fees, rather than an AMC fee alone being the competition to win lender work.
No change in their panel is necessary. No change in the manner in which they shop for fees is necessary. They continue to use a combination of a base fee, with appeals for fee upgrades for the tough ones as they occur. The low fee providers don't have any more alternatives for higher fees on 04/01 than they had on 03/31, so they'll obviously continue on as before. The only thing that changes is appraisers can't blame their fee problems on the lack of specific disclosure of their fee to an apathetic borrower.
What indication does anyone have that borrowers are outraged that fee appraisers only get paid $300 for a 1004?
If regulators were concerned about appraiser pool available to borrowers,the regulators should be concerned about the low fee result of AMC model driving many good appraises away from GSE work through AMC's as well as seeing the lower fee appraisers taking on enormous volume resulting in short time spent on reports with any resulting short cuts. If regulators are not concerned about that, that is fail on their part- they do not have a good record of listening to those on the front lines, they did not listen to the appraiser petition about lender pressure pre housing market collapse and they did not listen to those auditors trying to warn about Madoff. Their track records is clean up after a mess, not make sensible moves to prevent it.
This was never about borrower outrage though you try to make it about that. But since you went there-borrowers are complacent about fee splits because the borrower is kept in the dark about HOW a fee split can influence he way their appraiser is selected, such as bid out email like a flea market to cheapest .
Borrowers do not see fee splits, in states that require disclosure till after they get the appraisal, and even then they still have no idea HOW the appraiser was selected, aka that a more experienced or competent appraiser might have been available but denied the assignment because they charged $20 more ( covered by what borrower paid ).
THAT might get borrower' attention, disclose in full the manner of appraisal selection such as email bids or texts sent on an iPhone with fast click or cheapest bid wins the order. ..This should be disclosed upfront, when borrower applies for loan and pays appraisal fee.
Do you think a borrower might be outraged, or concern, if there was actual transparency and honesty about appraisal ordering presented to them at time of application such as below?
Borrower- disclosure Your appraisal fee is $450 . This lender uses an AMC as it relieves the lender of burden of assigning. The lender gets the AMC service at no cost to them, because AMC makes their overhead and profit by assigning to a lower fee fee appraiser. You will see none of the savings back if your appraisal is assigned at any fee level, for example, $250.
Your appraisal may be bid out for this assignment by text , app, or email and assigned to a lower fee vendor. Though it is represented fee does not matter since the work only has to meet minimum standards, there can be a great deal of difference among appraiser competence and experience. Your lower fee selected appraiser will likely be doing a large volume of work to compensate for the lower fee , meaning they will spend as least time possible on your appraisal"
You think a borrower might care if they got the above disclosure at time of application?
