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Request for Information Regarding Promoting Access to Mortgage Credit

Francois K. Gregoire

Senior Member
Joined
Jan 14, 2002
Professional Status
Certified Residential Appraiser
State
Florida
Some here are very interested in the disclosure of "appraisal fee" splits between Appraisal Management Companies and Appraisers. Here's an opportunity to inform the CFPB and possibly affect their rule making.
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The CFPB is seeking public comment on a number of items related to Executive Order 14393—Promoting Access to Mortgage Credit. Some of these are appraisal related and may be of interest.

Request for Information Regarding Promoting Access to Mortgage Credit
Excerpt:

Zero Tolerance

Estimates of charges paid to creditors or mortgage brokers (or their affiliates) and transfer taxes are in good faith if the consumer is not charged more than the estimates. Estimates of third-party charges are also subject to zero tolerance if the creditor requires the consumer to use creditor-selected service providers (rather than permitting the consumer to shop for third-party service providers).

In response to the November 2019 RFI, several commenters stated that transfer taxes and third-party appraisal fees are particularly difficult for creditors to estimate within three business days of application and that the CFPB should not include these fees in the zero tolerance category.
 
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Some here are very interested in the disclosure of "appraisal fee" splits between Appraisal Management Companies and Appraisers. Here's an opportunity to inform the CFPB and possibly affect their rule making.
----
The CFPB is seeking public comment on a number of items related to Executive Order 14393—Promoting Access to Mortgage Credit. Some of these are appraisal related and may be of interest.

Request for Information Regarding Promoting Access to Mortgage Credit
Excerpt:

Zero Tolerance

Estimates of charges paid to creditors or mortgage brokers (or their affiliates) and transfer taxes are in good faith if the consumer is not charged more than the estimates. Estimates of third-party charges are also subject to zero tolerance if the creditor requires the consumer to use creditor-selected service providers (rather than permitting the consumer to shop for third-party service providers).

In response to the November 2019 RFI, several commenters stated that transfer taxes and third-party appraisal fees are particularly difficult for creditors to estimate within three business days of application and that the CFPB should not include these fees in the zero tolerance category.
I have emailed them and the White House and my senator.

I'll try again. They did email me back. My senator didn't. She won't get my vote in August.

She will probably win governor. I know secretary of state. She will probably be his new boss. I won't vote for her.

The secretary of state in TN has served under both democrat and republican and done well. He is republican.
 
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I really thought CFPB or FTC would jump in with both feet.

That is where me and my girlfriend Joan had so many problems on commingling of fees. Beautiful woman but wrong perspective.
 
I have said this 100 times at least. The BORROWER does not care. They know up front what the appraisal fee will be. They agree to it. They do not give a crap about appraisers or AMCs. They want to buy a house. Anyone who believes that borrowers will stand up and come to the rescue of appraisers.

When you buy nearly any product the price will be split many ways. You buy furniture, the manufacturer gets part, the store gets some, the trucking company gets some, the lumber company gets some. When someone buys a car do they want to know how the price is split up. Salesman, dealer, shop personnel, delivery, prep crew, rent, overhead. Who cares? I want the car. When I buy a house and I have bought dozens, I could not care less how much the appraiser gets, the home inspector, the painters, the carpet layers.....I do not care. I have agreed on a price and paid it.

This idea that anyone other than appraisers care about how any of the fees are split simply is ignoring reality. Do get the AMCs get too much....any do. This argument has been going on for 30 years and nothing has changed.
 
I have said this 100 times at least. The BORROWER does not care. They know up front what the appraisal fee will be. They agree to it. They do not give a crap about appraisers or AMCs. They want to buy a house. Anyone who believes that borrowers will stand up and come to the rescue of appraisers.

When you buy nearly any product the price will be split many ways. You buy furniture, the manufacturer gets part, the store gets some, the trucking company gets some, the lumber company gets some. When someone buys a car do they want to know how the price is split up. Salesman, dealer, shop personnel, delivery, prep crew, rent, overhead. Who cares? I want the car. When I buy a house and I have bought dozens, I could not care less how much the appraiser gets, the home inspector, the painters, the carpet layers.....I do not care. I have agreed on a price and paid it.

This idea that anyone other than appraisers care about how any of the fees are split simply is ignoring reality. Do get the AMCs get too much....any do. This argument has been going on for 30 years and nothing has changed.
And your point is?

The borrower does care lol. Ever heard of lendingtree......? What do borrowers do...they search and compare lenders for the best rate and the lowest closing costs. The other issue is that most buyers are first time buyers or are part of the mortgage process every 8 years. Therefore they are ignorant to the process.

Eventhough they are ignorant, that does not mean that they should not be protected.

The issue is that borrowers cannot pick and choose the lowest appraiser. So your examples are comparing oranges to apples.


I love you and George h. But it dumbfounds me as to why yaw are so much against this? Weird. It's like you want the big AMCs to win?

What's next..? Private equity buying hospitals, nursing homes, healthcare, etc. I guess some are ok with it as long as you own stock or equity in the Private equity.

It could be a positive for both the borrower and the appraiser, eventhough nothing comes of it? So what?
 
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And your point is?

The borrower does care lol. Ever heard of lendingtree......? What do borrowers do...they search and compare lenders for the best rate and the lowest closing costs. The other issue is that most buyers are first time buyers or are part of the mortgage process every 8 years. Therefore they are ignorant to the process.

Eventhough they are ignorant, that does not mean that they should not be protected.

The issue is that borrowers cannot pick and choose the lowest appraiser. So your examples are comparing oranges to apples.


I love you and George h. But it dumbfounds me as to why yaw are so much against this? Weird. It's like you want the big AMCs to win?

What's next..? Private equity buying hospitals, nursing homes, healthcare, etc. I guess some are ok with it as long as you own stock or equity in the Private equity.

It could be a positive for both the borrower and the appraiser, eventhough nothing comes of it? So what?
You don't care about the consumers paying "more" for an appraisal. You care about the AMC not paying you what you want or think is fair. If consumers shopped around for the lowest appraisal fee the AMC would pay even less. Consumers do not care how the fee is split. $200.00, $600.00, $900.00. Whatever the consumer pays...they do not care how much of it the appraiser gets.

I am not against appraisers being paid more at all.....but consumers simply don't care. If they did then lenders making sure the appraiser got more money would corner the market. This issue is for dreamers; I am a realist.
 
You must be kidding. "What's next..? Private equity buying hospitals, nursing homes, healthcare, etc.". the majority of these places are for profit.

Largest Privately Owned Nursing Homes in the U.S. by Size and Age​

The U.S. nursing home market is dominated by a small number of large chains, with Ensign Group, PACS Group, and Life Care Centers of America leading in facility count, while some of the oldest operators date back decades.

Current Leaders by Facility Count​

As of June 2026, the top 15 largest nursing home chains (by total facilities) are NursingHomeDatabase.com:

  1. The Ensign Group – 342 facilities, 14 states
  2. PACS Group – 280 facilities, 17 states
  3. Life Care Centers of America – 194 facilities, 26 states
  4. Genesis HealthCare – 187 facilities, 34 states
  5. Creative Solutions in Healthcare – 149 facilities, 12 states
  6. Saber Healthcare Group – 127 facilities, 12 states
  7. Triology Health Services – 124 facilities, 12 states
  8. Communicare Health – 121 facilities, 12 states
  9. Avir Health Group – 118 facilities, 12 states
  10. PruithHealth – 99 facilities, 12 states
  11. Good Samaritan Society – 92 facilities, 17 states
  12. American Senior Communities – 91 facilities, 12 states
  13. Legacy Healthcare – 89 facilities, 12 states
  14. Marquis Health Services – 88 facilities, 12 states
  15. Complete Care – 85 facilities, 12 states
 

What Is a Private Healthcare System & How Does it Work?​

A private healthcare system consists of healthcare services provided by privately owned hospitals, clinics, and medical centers. It is primarily funded through private health insurance, out-of-pocket payments, employer-sponsored plans, employee health benefits and membership medicine programs.

While private healthcare providers are usually pricier, they also offer premium benefits like not having to wait too long for an appointment and accessing cutting-edge treatments.

Statistics on the U.S. individual health insurance in the public and private healthcare markets from 2020 to 2030.
Source: Grand View Research

To help you fully understand the processes and components of private healthcare, let’s talk about the facilities that operate within it, the payment models patients can use, and more. Here’s how private health care works.

The US private healthcare system includes many diverse types of providers from private hospitals and clinics to specialized medical centers that operate both in for-profit and non-profit structures.

Many private hospitals and facilities use advanced diagnostic technologies and offer complex surgeries. Since these are not available in public systems, private providers sometimes partner with larger healthcare networks to give more patients access to specialized care.

The costs of private health care make the system stand out. There are usually 3 payment models available, including private insurance, which covers preventive health and routine care, employer-sponsored plans, which offer broader coverage, and direct payments, whereby patients cover their own costs for premium services like personalized concierge medicine.

Private healthcare usually thrives in terms of specialized treatments and superior care options like preventive care. Using cutting-edge medical technologies, providers within these systems can do quicker consultations, better diagnostics, surgeries, and follow-ups.

In the private healthcare market, medical providers usually need to compete with each other to attract new patients and insurance companies. This ambition leads to more innovation and discoveries of better healthcare delivery methods.

Before exploring the pros and cons of private healthcare, it’s essential to understand how private vs. public healthcare differ in structure and funding. From quicker access to specialists and individualized treatment programs catered to each patient’s needs, the benefits of private healthcare are many. Yet, the system also has its disadvantages, particularly in terms of accessibility and costs.

If you’re considering putting your health in the hands of the private healthcare system, you’ll need to weigh both its pros and cons to make an informed decision, so let’s start dissecting it.

Infographic showing that the U.S. has the highest healthcare costs globally, including public and private healthcare in addition to voluntary spending.
Source: Statista

While the benefits of private health care are too many to count on one hand, we’ve gathered the 5 most valuable advantages you should know about. Let’s talk about them and understand why private healthcare is worth the investment.

Private healthcare works faster and more efficiently. Within this system, wait times are reduced, enabling patients to visit specialists and have diagnostic testing completed more quickly. This is an especially valuable benefit for executives and busy professionals who need immediate, efficient medical attention.

Instead of being assigned providers within a public network, patients are free to select the physicians, hospitals, and treatment regimens that best suit their specific health needs.

Private facilities often provide state-of-the-art care options that would not be accessible in public systems. They are usually the first to adopt new technologies and creative treatments, helping them be more competitive in terms of quality and service.

Private healthcare offers personalized medical care plans that cater to each patient’s needs, with an emphasis on wellness and prevention. Using proactive screenings and even genome testing, this preventive medicine model lowers long-term risks of developing health problems.

As part of their corporate health benefits, many companies offer private healthcare options to their executives. This not only helps them improve employee retention, productivity, and overall job satisfaction but also helps them attract top talent.

The disadvantages of private healthcare system aren’t too many, and they don’t outweigh its benefits. Still, they are worth keeping in mind when debating whether to join the world of private medicine or not. So, let’s cover them as well.

All the advanced diagnostics and premium quality of care within the private healthcare system come at a cost. Insurance usually doesn’t cover the full extent of subscription medical care plans, so out-of-pocket expenses are likely to appear.

You should also consider the premiums and deductibles of your private insurance to get the full picture. While affordability is a real concern, the quality of private healthcare truly speaks for itself. To those who value their health above all, this investment is undoubtedly worthwhile.

Private insurance isn’t an all-inclusive deal. There will be instances where certain surgeries, experimental therapies, and pre-existing conditions will not be covered by certain private insurance plans. So, before you choose a provider, make sure that you know every detail about your insurance policy.

Having covered the advantages and disadvantages of private health care, let’s understand the other side of the story. If you don’t choose private healthcare, where does it leave you?
 
Choose Your Battles and Appraisers Fee's are not one the CFPB is going to change.
 
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