More AMC and PDC Bull

[Carnivore]

Now I get what the GSE's our doing, I dont hate or love them. They have made res appraisers more efficient, and caused a lot of appraisal work.

 

[George Hatch]

Nothing to do with pay. They are in the appraisal business. They should be held to an ethical standard. Of course, one of the many revaa reps that represented them at state board meetings told them their AMCs have no responsibility for the appraisal reports they produce. Sounded like they liked it that way.

It's the lenders who are responsible (on the regulatory basis) for their usage of appraisals, including the selection and engagement of the appraisers with whom they do/don't choose to engage. And their manner of engagement. Says so right in the regulations for which they are required to comply.

USPAP applies to individuals engaged in Appraisal Practice. That is a defined term. The "apply to individuals" element is a big deal, too. Your accountant or your janitor or cafeteria lady may work for your fee shop but that doesn't make them responsible for complying with USPAP. USPAP doesn't apply to the conduct of the organization, only to the appraisers who work there.

Certain aspects of what AMC *employees*do such as *establishing* appraisal policies or reviewing appraisals or performing appraisals do fit the definition of Appraisal Practice but 95% of more of what most AMCs do does not fit that definition. In USPAP parlance what they do fits within the broader definition of "Valuation Services" (excluding appraisal practice) to which USPAP does not apply.

Either way, USPAP itself does not address fees or the business aspects of employing or engaging appraisers, nor does it apply to the business aspects of operating as a self-employed appraiser. The exceptions to that being prohibitions relating to appraiser conduct *in response* to requests for them to engage in unethical conduct. Such as accepting assignments with contingent fees or unreasonable SOW or returning predetermined results or client advocacy and such.

If you're looking for a non-regulatory ethical standard for how clients who engage self-employed appraisers should comply that's going to be a fail. But hey, maybe you can contrive one on your own and then sell them on the merits of why they should submit to the fee appraisers.

 

[George Hatch]

Now I get what the GSE's our doing, I dont hate or love them. They have made res appraisers more efficient, and caused a lot of appraisal work.

They're basically bankers, not an appraiser entity. Their previous requirements imposed appraisers on the lenders as an unfunded mandate, from which appraisers have benefitted greatly for many years. We are very much a special interest group who have benefitted greatly from their policies as well as govt rules, regulation and law. And now we're getting very angry when some of those enabling requirements are being rescinded by the users.

I don't get mad at brokers for acting like brokers. I don't get mad at lawyers acting like lawyers. I don't get mad at bankers acting like bankers and I don't get mad at the GSEs for acting in that role. I accept the fact that nobody other than appraisers act like appraisers.

 

[chad hampton]

Well, at the very least, since the profession is too cowardly to do anything to form standards for AMC’s, it would be nice if the state boards enforced their standards.

At least state boards knew enough to write AMC legislation.

 

[George Hatch]

In what world could appraisers impose any standards of conduct on their clients? Because it isn't in this world.

Bravery or cowardice ain't got nothing to do with it. Appraisers are wholly incapable of imposing their will on even their peers, much less their clients.

"This is a union picket line and you cannot cross it or else we'll be very, very angry with you"​

"Hold my beer"​

 

[DWiley]

At least state boards knew enough to write AMC legislation.

State boards do not write the legislation.

Most state legilslatures adopted AMC laws for the same reason they adopted appraiser credentialing - they were forced to.

 

[TerryRohrer]

At least state boards knew enough to write AMC legislation.

Not how that happened. "under Section 1473 of the Dodd-Frank Act, states are required to create registration and supervision programs for Appraisal Management Companies (AMCs) operating within their jurisdiction. While not directly forced, if a state fails to set up these regulations, AMCs are barred from handling federally regulated appraisals in that state."

Note the requirement is to "create registration and supervision programs." Silent as to the enforcement of anything, and that is exactly how my board operates...they only hassle appraisers, and seldom hassle those whose licenses should be revoked.

 

[chad hampton]

State boards do not write the legislation.

Most state legilslatures adopted AMC laws for the same reason they adopted appraiser credentialing - they were forced to.

They did write rules though

But your friends have nothing to worry about, they won't enforce either.

 

[chad hampton]

Not how that happened. "under Section 1473 of the Dodd-Frank Act, states are required to create registration and supervision programs for Appraisal Management Companies (AMCs) operating within their jurisdiction. While not directly forced, if a state fails to set up these regulations, AMCs are barred from handling federally regulated appraisals in that state."

Note the requirement is to "create registration and supervision programs." Silent as to the enforcement of anything, and that is exactly how my board operates...they only hassle appraisers, and seldom hassle those whose licenses should be revoked.

True, they were forced to.

 

[glenn walker]

For the same reason there isn't an ethical requirement for appraisers to work for less, there also isn't an ethical requirement for the AMCs to pay more. Leastwise, not after the feds issued their interpretation of C&R.

90% to 95% of registered AMCs are owned by licensed appraisers which just have more appraisers then allowed before your required to register as a AMC.

These were previously known as the large fee shops that engaged many appraisers before the rules on how many appraisers changed-allowed under one licensed supervisor.

The 5% to 10% of the well known AMCs are the ones that control volume going through the major lender's and money center banks and the other AMCs are many small fee shops.