My prediction on 3.6

[George Hatch]

Use whatever label you want. The lender purchases, the AMC provides. Unless you think the AMC isn't providing.

 

[J Grant]

Use whatever label you want. The lender purchases, the AMC provides. Unless you think the AMC isn't providing.

The AMC provides its AMC service to a lender FREE of cost, at the expense of the appraiser.

How can the lender purchase something when they have not paid a cost for it?

Nor has the lender disclosed to the borrower upfront, on the loan application, that the borrower's paid appraisal fee covers the AMC service. (the basis for the consumer lawsuit )
You can argue that the co-lender covers the appraisal service, which is a charge to the borrower and is disclosed upfront on the loan application. An appraiser charging the lender for an appraisal, which the borrower covers, pays for a service the borrower needs ( an appraisal) to close their loan.

The borrower does not need the AMC service to close a loan. It is something the lender benefits from.

 

[Dublin ohio]

The AMC provides its AMC service to a lender FREE of cost, at the expense of the appraiser.

How can the lender purchase something when they have not paid a cost for it?

Nor has the lender disclosed to the borrower upfront, on the loan application, that the borrower's paid appraisal fee covers the AMC service. (the basis for the consumer lawsuit )
You can argue that the co-lender covers the appraisal service, which is a charge to the borrower and is disclosed upfront on the loan application. An appraiser charging the lender for an appraisal, which the borrower covers, pays for a service the borrower needs ( an appraisal) to close their loan.

The borrower does not need the AMC service to close a loan. It is something the lender benefits from.

The whole premise of your "argument" is based on the assumption that if you cut out the AMC the appraiser will be paid the amount the AMC was getting. Possible but highly improbable

 

[J Grant]

The whole premise of your "argument" is based on the assumption that if you cut out the AMC the appraiser will be paid the amount the AMC was getting. Possible but highly improbable

Why is it improbable?

The lender charges a C and R fee to the borrower for the appraisal. Without the AMC getting a cut from a fee split, the appraiser would get that entire borrower-paid fee. The lender is not allowed to keep a portion of it.

 

[glenn walker]

The lender hires the AMC to manage their appraisals from ordering to delivery and review and interfacing with the appraisers so the lender is free to process and fund loans. Some keep talking like operating a AMC is simply keeping the money to just deliver reports which is ridiculous.

The staff model will replace the fee model because you don't pay staff the appraisal fees collected.

The fee model will be used in rural areas or on complex but avoided in Cities and high density Suburban areas. The math doesn't math on using the fee model and the AMCs will have staff and will outsourse the rest.

 

[George Hatch]

Why is it improbable?

The lender charges a C and R fee to the borrower for the appraisal. Without the AMC getting a cut from a fee split, the appraiser would get that entire borrower-paid fee. The lender is not allowed to keep a portion of it.

There is no evidence that appraisers will stop competing with each other . Nothing in D-F inhibits appraiser-driven fee competition.

 

[J Grant]

There is no evidence that appraisers will stop competing with each other . Nothing in D-F inhibits appraiser-driven fee competition.

Appraisers do not compete by bidding on low fees to win a regular lending order. Only the AMC's have appraisers do that.

When a lender pays the same C and R fee to their appraiser panel in a region, the lender does not pay some appraiers less than that, even if the appraiser offers it. I know that from firsthand experience. Appraiers compete on high-value or custom quote assignments. They tend to charge a similar amount for non-complex orders when an AMC is absent.

 

[George Hatch]

There is no evidence the AMC appraisers will stop competing with each other by fee. You've been told many times that AMC payouts vary by locale. That cannot happen if the AMCs wield complete control over the fees. That can only happen if the appraisers are competing with each other.

You don't need to believe any of the current or prior AMC personnel going all the way back when they speak of appraisers calling them and offering to swap fee for more work. All you need to do is apply some critical thinking of your own. How can AMC payouts be different by locale unless one of the variables in the supply/demand is different?

 

[J Grant]

There is no evidence the AMC appraisers will stop competing with each other by fee. You've been told many times that AMC payouts vary by locale. That cannot happen if the AMCs wield complete control over the fees. That can only happen if the appraisers are competing with each other.

Even when the AMC pays more in one region than another, the appraisers still make less $ due to the AMC split than when Appraisers in those regions deal with a lender directly.

If the AMC no longer gets compensated from a split of the appraisal fee, the AMC has no more incentive to shop by fees, thus the nature of the appraisers competing on fee would change.

 

[George Hatch]

There is no indication that the AMCs will ever stop shopping by fee. And again, you've been TOLD for years that the lenders have pitted AMCs against each other by fee. Which the lenders wouldn't do unless the amount of the total mattered to them.