More AMC and PDC Bull

[Zoe]

Who cares how much an appraiser would get paid if the lender could not pass the cost directly to the borrower? The lenders can pass the cost directly on to the borrower

I AM FINE WITH THE LENDER PASSING THE AMC COST ON DIRECTLY TO THE BORROWER !! I am not arguing against that !!

, I want the LENDER TO PASS ON THE AMC COST DIRECTLY TO THE BORROWER AS ITS OWN AMC FEE OR COST ITEM, SEPARATE AND APART FROM THE APPRAISER's fee (not bundeled)

Because that would remove the incentive for the AMC to drive down the appraiser's fee in order that the AMC gets a bigger split of the appraisal fee.

That is where HUD and fair housing comes into play. Lenders only have a small margin for variance based on certain items in truth in lending disclosures. Some items are concrete on disclosures, Some items can vary after initial good faith estimate without having to issue new good faith estimate to borrower. They have tolerance level though on some items. They can't vary much from initial disclosures to borrower.

I don't remember the tolerance level on how much they can vary on certain items on truth in lending disclosures, but it is not much. Lenders have little leadway they can vary on original good faith estimate but only on certain items.

If they break that threshold, they have to issue new good faith estimate. Borrower has few days to accept good faith estimate or go to another lender.

Some borrowers may have good faith estimates from several lenders. The borrower can pick and choose.

Lender has some play in like origination fee on how they can spend that money and be in compliance with truth in lending laws. In other words, lender can't spend origination fee on whatever based on truth in lending law.

 

[Carnivore]

I am pretty sure of this the more and more we go towards desk top AND fee;s the AMC CAN'T SUPPORT its Overhead They can't ---
------------------------------------------survive

What I received at my house from the mlail lady would stun all of you,

 

[Surf Cat]

How much would those appraiser get paid if the lender could not pass the cost directly to the borrower?

Dude..... the borrower has "always" paid for the appraisal.

It's "the lender" that ever since the hvcc was in enacted, then sunseted, that does not pay a cost for a service that is provided to them. J Grant has been pounding her head on the desk trying to get this through your guys's heads.

From a fairness and transparency standpoint, it should be mandatory that separate disclosure of the appraiser fee and AMC fee be noted in the disclosures. That is, if the borrower is to be expected to pay for the AMC cost. If the lender is going to take care of the cost of the AMC..... which they should ( they used to with the chief appraiser and review appraiser staff) that cost wouldn't need to be disclosed.

If the above were to happen, it would solve so many problems.

 

[J Grant]

I am pretty sure of this the more and more we go towards desk top AND fee;s the AMC CAN'T SUPPORT its Overhead They can't survive

The will survive just fine. It is the appraiser that wil have trouble surviving.

The AMC's can make up for any loss in volume of appraisals because AMC's will be doing the PDC collection for Fannie and Freddie in a waiver/value acceptance when a PDC is used !! (The appraiser gets nothing from a waiver but the AMC will when they handle the PDC )

And the AMC's will benefit from hybrids using a PDC, -the AMC can use low-paid data collectors and squeeze much higher appraisal volume from their deskbound staff appraisers- allowing them to fire more appraisers. As a way to further impoverish and marginalize the role of appraisers, while increasing the profits and role of the AMC, the GSE greenligjing of the PDC collection using non appra9sers is perrect!

We will be lucky if a portion of competent appraisers stay in demand for the segment of appraisal work that remains with mortgage lenders .I believe that will be the case for a while, anyway. The changes will still impoverish or disenfranchise a number of real estate license appraisers who rely on mortgage work.

 

[Surf Cat]

I am pretty sure of this the more and more we go towards desk top AND fee;s the AMC CAN'T SUPPORT its Overhead They can't survive

It was a bum rush to open an AMC as the shysters saw easy pickings. A legal scam.

You're right, the big AMC company would no longer exist. Not at 50 to $75 per report.

 

[J Grant]

Dude..... the borrower has "always" paid for the appraisal.

It's "the lender" that ever since the hvcc was in enacted, then sunseted, that does not pay a cost for a service that is provided to them. J Grant has been pounding her head on the desk trying to get this through your guys's heads.

From a fairness and transparency standpoint, it should be mandatory that separate disclosure of the appraiser fee and AMC fee be noted in the disclosures. That is, if the borrower is to be expected to pay for the AMC cost. If the lender is going to take care of the cost of the AMC..... which they should ( they used to with the chief appraiser and review appraiser staff) that cost wouldn't need to be disclosed.

If the above were to happen, it would solve so many problems.

Separate disclosure should be mandatory and made at the time of loan application

However, disclosure of a split of the appraisal fee still leaves the appraiser with less, $ and still leaves the AMC selecting appraisers by a low fee bid or quote. It might help prevent the most egregious of fee splits, however.

The real reform would be for the AMC to charge a line item separate cost charge to the lender for the AMC service, and the lender disclose it and charge it to the borrower, separate and apart from the appraisal fee (not comingled/bundled )

 

[Zoe]

I am telling you like this lawsuit coming from a borrower in California will have a impact. If those lawyers get that data from AMC and lender on fair housing, they will feed it into Artificial intelligence and let it do it's thing.

I can only imagine what AI can do on data you feed it from lenders. If it is true Morgan and Morgan are involved, they are going after deep pockets on truth in lending disclosures. They don't care about the appraiser.

 

[DWiley]

Separate disclosure should be mandatory and made at the time of loan application

The requirement to disclose at the time of application is exactly what has created the current situation.

As I have said many times, I wish disclosure of the fee breakdown was required. I do not think it would change anything related to appraisal fees, but it would end the debate.

 

[George Hatch]

Dude..... the borrower has "always" paid for the appraisal.

It's "the lender" that ever since the hvcc was in enacted, then sunseted, that does not pay a cost for a service that is provided to them. J Grant has been pounding her head on the desk trying to get this through your guys's heads.

From a fairness and transparency standpoint, it should be mandatory that separate disclosure of the appraiser fee and AMC fee be noted in the disclosures. That is, if the borrower is to be expected to pay for the AMC cost. If the lender is going to take care of the cost of the AMC..... which they should ( they used to with the chief appraiser and review appraiser staff) that cost wouldn't need to be disclosed.

If the above were to happen, it would solve so many problems.

The borrower pays for everything, not just the appraisal. They always have. Some of the payment comes up front and the rest is built into the monthly payment. There is no element of the deal that the borrower doesn't pay for. No element that is free to the borrower. That includes the AMCs fee, whether the borrower pays up front or over time - and with interest - over the life of the loan.

The cost of doing business is just that...business. The borrower wants to borrow someone else's money and it is on them to meet the various terms and conditions upon which the loan approval is granted. It is not on the lender to subsidize those costs of the transaction on behalf of the borrower.

 

[J Grant]

The requirement to disclose at the time of application is exactly what has created the current situation.

As I have said many times, I wish disclosure the the fee breakdown was required. I do not think it would change anything related to appraisal fees, but it would end the debate.

I agree that other than preventing the most egregious spits, imo the disclosure of the fee breakdown might accomplish little , as long as the appraisal fee includes the AMC fee as a bundled fee.

Which is why, as I have said hundreds of times in my post, I advocate for NO MORE BUNDLING OF THE AMC FEE WITH THE APPRAISAL FEE.

Make the AMC fee, when the lender uses an AMC , a separate line item charge, and if the lender passes that charge on to the borrower, so be it.