J Grant
Elite Member
- Joined
- Dec 9, 2003
- Professional Status
- Certified Residential Appraiser
- State
- Florida
That is why the "combo" of bundled fee must be changed on the regulatory side if the fee predation by AMCs is to be addressed.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.
The AMCs;s do not compete with each other the way normal businesses do, since typically none of the AMCs charge a hard cost to the lender. The lender in fact, does not benefit when an appraiser on the AMC panel is paid less. The lender passes the borrower-paid fee or an agreed-upon amount ( if the lender takes anyting off the top ) to the AMC regardless of what the appraiser is paid. The AMC's drive down appraiser fees not to compete for lender customers, the AMC's drive down appraiser fees because they are compensated from those fees and the less an appraiser gets, the more the AMC gets.