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Even if we want to say those are the only significant participants the point remains they are competitors with each other. They're competing for the same accounts. In the Lender/AMC relationships it is the lenders who do the buying, not the AMCs.

There is not one AMC-using lender that couldn't convert to a cost-plus scheme. Today, if they wanted to. If (for example) Solidify wouldn't do it then one or more of the others most certainly would do it, like ServiceLink. And if Servicelink did go to Cost-Plus they would most likely continue to shop appraisers by fee because if ServiceLink didn't offer their lenders the combo their competitors would step in to do it instead.
 
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Fernando said:
That seems to be the direction and I don't like how they can get to "collude" in affecting appraiser fees.
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They all use the same appraisers and they are getting their orders filled at whatever the fees is. I don't think that is colluding.

Whether or not looking for the cheapest is good or bad is a different question.
 
Whereas the other 190 AMCs are just paying the fees to maintain their registration status for the fun of it?

Appraisers are not competing with the AMCs for their fees; they're competing with each other. And like it or not, it only takes a few of your competitors to trade $10 in fee for more volume; then that becomes the new normal for that group. From the AMCs perspective, anyway.

Let us know when you guys stop hearing that "if you won't do it we'll just find someone else who will" ploy. We'll throw a celebration.
 
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If there is collusion, it is about how much they are going to charge the lender, not how much they are going to pay the appraiser.

From what I've seen, they have raised the fees charged to lenders by a good amount.
 
Joe Flacco said:
If there is collusion, it is about how much they are going to charge the lender, not how much they are going to pay the appraiser.

From what I've seen, they have raised the fees charged to lenders by a good amount.
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When they know how much appraisers are charging (one of the portals asked my fee and I assume info can be shared with all other lenders), the lenders will have advantage in setting fees.
 
George Hatch said:
How many portals do you need to prevent the allegation of the few dominating the market? More than 10? More than 50? More than 100? IRL a 100-portal channel is not narrow. Not when the example you keep citing form the 2021 spike didn't even handle 5% of Freddie-Fannie (only) volumes.

Don't forget, some of the LENDERS chose not to operate through AMCs. Thus demonstrating their own agency. We can't even blame the GSEs for what the originating lenders do. Nobody is forced to use an AMC and none of the lenders are forced to operate via the bundled fee model. If they're doing so it's because they want to do so. Unless/until appraisers persuade the politicians to strip that right from the lenders.
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A 100 portal channel IS narrow !!! considering that in every other business, including the commercial/private side of appraisal, there is UNLIMITED ordering on the demand side . In practicalitly, for res lending, which prohibited consumers from ordering, there were still thousands to tens of thousands of loan officers and mortgage brokers ordering prior to HVCC.

Plus, you have not absorbed anyting if you think 100 AMCs;s are distributing the volume even close to equally. Of course, the problem is that even 100 AMCs in a state is a very narrow channel, considering that prior to that, there were thousands of loan officers on the demand side ordering AND those loan officers had no incentive to drive fees down since they did not keep a share of the fee split.

The reality that condensing the former larger demand into a hundred or even two hundred AMC's in a state was demonstrated in real time immediately following HVCC when it prohibited individual loan officers from ordering and fees were cut in half overnight. How ironic that Fannie/Freddie allows those same loan officers to estimate the target value they need in a loan in a WAIVER/value acceptance! ( as long as it falls in a range per the GSE )

Appraisal fees paid by AMCs were cut in half practically overnight following the HVCC, which shows the immense leverage AMCs have from a narrow demadn channel. I have no idea why you are so intent on trying to prove otherwise - your theoretical arguments do not match the reality.

We know an AMC is not required for eldners, so there is no need to repeat it. The lenders flock to the AMC's because it relieves them of admin and costs them nothing, since the cost is borne by the borrower and taken out of appraiser compensation via the bundled fee.

Do you believe the AMCs would have such a huge market share if lenders had to pay a hard cost to use them ? Do you think AMC's would be keeping $250 in a fee split, or that a lender might pay instead $75 a report if the lender had to pay a cost ? ( even if such cost was then added to borrwor column.]

Plus, a lender can own an AMC under a division, though those fees to appraisers from captive AMCs are typically better than the bid model AMC's
 
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