No College Degree for Cert Generals or Residential Appraisers

[J Grant]

Well I am waiting , Tell me the reasons I know the reasons I just want to hear what you think

Too expensive, too distracting from their main income job, and most areas of RE have not been adversely wrt fees the res license side of appraisal has been.
There may be other reasons you are free to add them!

 

[George Hatch]

D Wiley tries to sell it that there are hundreds of active AMCs ( no monopoly) yet anybody who does AMC work finds that patently false. A very limited number of companies assigns the volume, and the small players might order a dozen at most a year. When I did AMC work, the small companies might order under 6 a year and the limited amount of large companies had hundreds of orders a year , if one bids low enough. ..

The next time you make an assertion you might consider actually looking for the answer instead of pulling one out of thin air. The ASC registry shows 338 of them but some are inactive. The download shows 211 actives. That's just for your state.

 

[George Hatch]

Now your next attempt will be to say that just because there's a license doesn't mean they're doing anything. But the next logical question after that - which I don't assume you would think to consider - is why any entity would maintain an AMC license with your state unless they were doing at least a little business as an AMC? What would be the point?

 

[gregb]

The AMC did not get leverage in the CG markets because commercial lending post does not have the same regulatory bans on who orders the appraisal that Residential mortgage lender work does.

Wrong...

When loan officers were banned from ordering commercial appraisals​

Date / Trigger:

• The restrictions trace back to Title XI of FIRREA (1989), but they were made explicit and strictly enforced after the December 2010 Interagency Appraisal & Evaluation Guidelines (IAG).
• Banks were told they must have absolute appraisal independence and remove anyone with a “production role” from appraisal ordering.

Production staff explicitly includes:

• Loan officers
• Mortgage brokers
• Anyone whose compensation depends on loan volume

Why:
Regulators determined that allowing production staff to select or influence appraisers was a conflict of interest and contributed to inflated valuations prior to the financial crisis.

 

[J Grant]

The next time you make an assertion you might consider actually looking for the answer instead of pulling one out of thin air. The ASC registry shows 338 of them but some are inactive. The download shows 211 actives. That's just for your state.



View attachment 105286

Please re-read my post.
I SAID there are several hundred AMC s regisred and some of them inactive. I ALSO said that despite this, only a small number of the registered AMC's have the volume.

Do you deliberately try to misrepresent what I write? I can't understand it.

 

[George Hatch]

And after 2007 the trainee hiring slowed down. It became a non issue when the HVCC passed.

Explain this : Before the HVCC, the SAME SUPPLY of appraisers had no problem collecting C and R fees from mortgage clients. Immediately after the HVCC the SAME SUPPLY of appraisers saw fees cut in half, then the lenders fled en masse to HVCC. This kills the nonsense that the low AMC fees are due to an oversupply in the past of trainees.

The AMC did not get leverage in the CG markets because commercial lending post does not have the same regulatory bans on who orders the appraisal that Residential mortgage lender work does. The same goes for private residential work, where an owner or RE agent ( or anyone ) is free to order an appraisal. The split of the appraisal fee on the HUD allows a big market share of AMC;s in res lending because it provides a free-of-cost AMC service to the lenders.

Factually incorrect. The FRTs banned MB-originated appraisals 15 years prior to the HVCC. And for exactly the same reason - it's a conflict of interest.

No, the real reason the AMCs never came to dominate my side of the business is because we didn't build the big oversupply. They *couldn't* just go find someone who would work for half because there weren't enough alternative CGs to be shopping from - relative to the long term demand.

In my state the number of SLs+CRs went from 5,995 (in 2001) to 11,267 (in 2007). I know this because I kept track each year.

During that same period, the number of CGs went from 3489(2001) to 3389 (2008). THAT's why AMCs were unable to do the the CG trade what they did to the 1-4 markets for services.

 

[George Hatch]

Please re-read my post.
I SAID there are several hundred AMC s regisred and some of them inactive. I ALSO said that despite this, only a small number of the registered AMC's have the volume.

Do you deliberately try to misrepresent what I write? I can't understand it.

Anticipated in advance (because you ain't that quick and you ain't that deep) and answered in #203.

If you want to say 2% of the AMCs in your state control 60% of the market and they're operating as a criminal conspiracy that demonstrates a fairly dazzling degree of paranoia.

 

[J Grant]

Wrong...

When loan officers were banned from ordering commercial appraisals​

Date / Trigger:

• The restrictions trace back to Title XI of FIRREA (1989), but they were made explicit and strictly enforced after the December 2010 Interagency Appraisal & Evaluation Guidelines (IAG).
• Banks were told they must have absolute appraisal independence and remove anyone with a “production role” from appraisal ordering.

Production staff explicitly includes:

• Loan officers
• Mortgage brokers
• Anyone whose compensation depends on loan volume

Why:
Regulators determined that allowing production staff to select or influence appraisers was a conflict of interest and contributed to inflated valuations prior to the financial crisis.

Put another way, then - the regulated lending segment of commercial, where loan officers are banned from ordering appraisals, is a far smaller portion of the total appraisal work compared to resiednetial. Does a commercial loan close with a HUD statement with a HUD bundled fee on it?

Clearly, the number of commercial assignments were too small for AMC's to have the kind of leverage that occurred on the res side.

 

[J Grant]

Factually incorrect. The FRTs banned MB-originated appraisals 15 years prior to the HVCC. And for exactly the same reason - it's a conflict of interest.

No, the real reason the AMCs never came to dominate my side of the business is because we didn't build the big oversupply. They *couldn't* just go find someone who would work for half because there weren't enough alternative CGs to be shopping from - relative to the long term demand.

In my state the number of SLs+CRs went from 5,995 (in 2001) to 11,267 (in 2007). I know this because I kept track each year.

During that same period, the number of CGs went from 3489(2001) to 3389 (2008). THAT's why AMCs were unable to do the the CG trade what they did to the 1-4 markets for services.

A lower supply helped, but I doubt that was the main reason. What are the stats for the volume of work funneled for commercial work vs the volume on the res lender side, through AMC 's?

Some commercial appraisers of course, do res lending work and some even do it for AMCs .

 

[gregb]

THAT's why AMCs were unable to do the the CG trade what they did to the 1-4 markets for services.

Lenders in my market maintained control of commercial assignments, apparently unwilling to turn over appraisal management to AMC's.