• Welcome to AppraisersForum.com, the premier online  community for the discussion of real estate appraisal. Register a free account to be able to post and unlock additional forums and features.

More AMC and PDC Bull

The AMCs interests include clearing a profit from their operations but they can't even get the account without first competing for it. Nor can they retain the account without continuing to compete for it on the ongoing basis.

Not to mention your repeated allegations of "unqualified" and "incompetent" in those appraisals even though 90% or more of everyone has been doing most of their work via those conduits.
OMG---- yes the AMC interst includes clearing a profit.

My argument is the AMC should get tehir profit by charging the lender a cost charge for the AMC service. If the lender passes that charge on to the borrower, so be it.

However, the current system sees the AMC profit is borne by the appraiser getting a much lower appraiser fee when bundled with the AMC charge in the appraisal fee. The AMC profit in this system is likely very usorious compared to similar management fees ( usually 10-20% ) And We can predict that if lenders had to pay the AMC a cost for an appraisal order processing, it would likely be unfirom in order to pass it on to the borrower, not a profit from a bidding war to sqwueeze a vendor down.
 
The AMCs interests include clearing a profit from their operations but they can't even get the account without first competing for it. Nor can they retain the account without continuing to compete for it on the ongoing basis.

Not to mention your repeated allegations of "unqualified" and "incompetent" in those appraisals even though 90% or more of everyone has been doing most of their work via those conduits.
The AMC's have a very different playing field of competition, but who cares how they compete, as long as they don't get their profit by gouging the appraisers' fee as low as possible .

Again, what would the AMC charge to the lender look like in a $ amount without the AMC being able to bundle it as part of the appraisal fee ?

Have you seen some of these AMC reports? I have. And some are awful., But even if the AMC uses competent appraisers for a number of assignments, so what? The AMC is gouging the appraiser's fee from competent appraisers as well due to the bundled fee split model of the appraisal fee.
 
Oh come on...
I know it is Friday, but the issue is not an unlicensed vs licensed lawyer or doctor...I am free to pick licensed lawyers and licensed doctors!! Thus, a licensed doctor or licensed lawyer operates in a free market enviromnent with access to unlimited clients or patients.

But a borrower for a loan is not free to pick a licensed appraiser, and even the loan officer for the lender is not free to pick a licensed appraiser. The licensed appraiser operating within the realm of mortgage lending, therefore, has a limited set of buyers due to these restrictions. Thus, the appraisers for mortage work are not operating in a free market supply and demand system; thus, the C and R ruling made to protect fees - which became corrupted in the second HVCC ruling and thus a fail for the AMC side wrt appraisr fees when bundled with the AMC charge.
It's literally none of the borrower's business (or the loan originator) which appraiser the lender selects or why. They're both 3rd parties to that transaction. Paying for the appraisal only means they appraiser got paid. You know this.

Neither the borrower nor the loan officer are qualified to engage the appraisals the lender is using. I can agree with you that the final rule on C&R was contrary to the intent of the HVCC and D-F, but that doesn't alter the fact that they did set the rule that way and the lenders are free to continue to operate that way unless/until prohibited otherwise. None of these facts are in dispute.

We can all want "what should be" in perpetuity. In the meantime there remains the "what is" since the implementation of D-F. Which will continue indefinitely until its prohibited.
 
Here's what it's all about in a nutshell from AI. My bold for emphasis. Appraising is a unique occupation, limited to whom we can market our services to.

Is capitalism unfair in today's modern world?

In many ways, modern capitalism can be unfair, but it is not inherently unfair in every case . The fairness depends a lot on whether markets are competitive, laws are enforced evenly, and whether gains are broadly shared rather than concentrated at the top.

Why people call it unfair

A common criticism is that capitalism often produces large income and wealth gaps, especially when wages stagnate while top incomes rise. It can also reward inherited wealth, market power, and political influence, which makes the “game” feel rigged for people without those advantages.

Why others defend it

Supporters argue capitalism is fair in a process sense because people can trade voluntarily, compete, and keep the rewards of risk-taking and effort. They also argue it has lifted huge numbers of people out of absolute poverty and created more overall prosperity than centrally planned alternatives.

The modern reality

In today’s world, capitalism is usually mixed with government rules, taxes, and social programs, so the real question is not “capitalism or not,” but what kind of capitalism society allows. When regulation is weak, monopolies grow, wages lag, and inequality feels more unfair; when rules are strong and competition is real, capitalism can be more broadly beneficial.

So the best short answer is: capitalism is often unfair in practice today, but that unfairness usually comes from how it is structured and regulated, not from the basic idea of market exchange itself.
 
The lenders operate in a heavily regulated business environment. THEY are not free to operate without restraints. They still retain some discretion, though. Much to our chagrin.
 
Okay let's all agree seperation of fee's on disclosures will result in higher fees to appraisers. Now that part was easy now what geniuses will offer just who initiates the new disclosure and how it's made a new guideline for lenders.

I don't think any appraiser is against seperation of fee's so now it's just getting it implemented.

Unfortunately the hypothetical that Fee's will increase to appraisers is still just a hypothetical and won't be known until it's tested in the real markets.
 
I was just told by a fairly large mortgage bankers funding manager that the seperation of fee's is not prohibited by any of the regulatory agencies and most lenders already seperate the fees on their final disclosures but some may not.

She doesn't know which lenders do or don't separate the fee's but if it was a issue with borrowers they and not appraisers would be the ones to get change made with regulators and so she's kinda confused as to whose being damaged.
 
WRT the assumption that consumers will embrace higher fees for appraisers, I would much rather be wrong (in disagreeing) about that than to be right.
 
WRT the assumption that consumers will embrace higher fees for appraisers, I would much rather be wrong (in disagreeing) about that than to be right.
No matter what if she's correct it would be a consumer group maybe filing complaints to CFPB or other regulators that more clearly defined disclosures need to show what the appraisers actually receive out of the total collected. It appears the Lenders are collecting the total not the AMC and then lender pays the AMC to distribute the appraisers part and keep the remaining money.

Finally that's as I recall how DW also said the former AMC he worked for did it too but no matter what it's the lender whose responsible to create the borrowers disclosures not the AMC. Now it's just the hypothetical assumption that lenders would pay higher percentages of what's being collected to the appraisers.
 
We will see how that lawsuit works out in California.
 
Find a Real Estate Appraiser - Enter Zip Code

Copyright © 2000-, AppraisersForum.com, All Rights Reserved
AppraisersForum.com is proudly hosted by the folks at
AppraiserSites.com
Back
Top