And they're getting away with that due to the effective lack of legal prohibitions against shopping by fee.
Federal Register guidelines on appropriate appraiser selection methods. You perhaps slept through the past two decades of epic AMC industry racketeering.
An institution’s selection process should ensure that a qualified, competent and
independent person is selected to perform a valuation assignment. An institution should
maintain documentation to demonstrate that the appraiser or person performing an evaluation is competent, independent, and has the relevant experience and knowledge for the market, location, and type of real property being valued. Further, the person who selects or oversees the selection of appraisers or persons providing evaluation services should be independent from the loan production area.
The other pertinent quote follows:
Moreover, the Guidelines stress that an institution should not select a valuation method or tool solely because it provides the highest value, the lowest cost, or the fastest response or
turnaround time.
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That's not even the most important news. Federal injunction on stopping shut down of CFPB appears to be invalidated by recent SCOTUS ruling.
Which means C&R rules from DF Reg Z are or will be soon back in effect.
And the AMC industry is currently or soon to be in clear violation of customary and reasonable billing regulations, subsequently exposed to liability and federal penalties for;
$10,000 per instance, and $20,000 per recurring instance, DAILY RECURRING fines, for failure to pay C&R billing rates to appraisers. Per each individual a.m.c. You know, the agents of the lenders whom act on behalf of the lender, and can stack liability on not just their own companies, but behalf of the lenders they provide agency for.
Let's blow some dust off those old brain files shall we. See if you can still lie to yourself and everyone else about what free market principals are and are not, what racketeering is and is not, what fair consumer and fair vendor engagement principals revolving around standard business ethics are, and are not, as you pontificate in this soap box and limited hangout fish bowl.
Mike Kennedy over a decade ago from this forum;
Please advise when the fictitious cfpb safe harbor fee interpretations will be rescinded.
You can keep on lying if you want to. We know you're lying. You know we know you're lying. And you continue to lie anyways.
Improperly co mingled fees.
