Request for Information Regarding Promoting Access to Mortgage Credit

[glenn walker]

Write letters that's fine but it's naive to really believe it matters it's just not on the priority list of regulators.

 

[NC Appraising]

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.

So what's your beef with it? Why are you so concerned? That's the part that I do not get? What do you have against transparency? Again, strange....

Again, consumers DO care. Lending tree.
They just do not break it up on a line item basis.

One lender has a interest rate of 6% with $5000 in closing costs.

The other lender has a interest rate of 6% with $4,800 in closing costs.

Two hundred bucks is two hundred bucks.....that's a lot to some people. What let the AMC have it? Theives.....dishonest....

Then you have the GSEs bragging about saving BORROWERS over a billion in appraisal fees due to waivers.

i guess the borrower doesn't care about that either?

All else being equal....which one are you going with?

I don't care what the appraiser gets.

What i want is transparency.

 

[djd09]

then the cfpb shouldn't cry about 'inacurrate' or 'biased' appraisals...because you get what you pay for

 

[J Grant]

I care what the appraiser gets. There is no shame in that, and I am sick of the schills trying to make appraisers feel like hypocrites for it.

At the same time, we can ALSO care about transparency. I personally care far less about the consumer overpaying because, in most cases, they did not overpay - what happened is they were not informed that a big chunk of their check would go to a middleman, AMC.

What they also were not informed about was how their order would be shopped flea market style by the AMC to the lowest bidder. Even with these lawsuits, the borrowers might not be aware of that aspect. I bet a whole lot of them would feel ripped off if they knew that.

This is the borrowers' appraisal, the valuation of their house or a home purchase; it is not shopping for sneakers on Amazon.

I have had many RE agents complain about the bad AMC appraisers they see that come into PBeach County, 2 counties away, and knew nothing about the market.

 

[NC Appraising]

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

My AI....

Private equity (PE) firms have injected approximately $1 trillion into the U.S. healthcare system over the last decade, acquiring over 450 hospitals, hundreds of nursing homes, and thousands of medical practices. While proponents argue this capital modernizes struggling facilities and streamlines operations, extensive clinical and financial data show that the PE business model heavily impacts patient care, operational costs, and facility stability

Impact on Nursing Homes
Nursing homes have been primary targets for PE "roll-ups" (buying and consolidating multiple local facilities). Peer-reviewed studies highlight severe consequences for long-term care residents: [1, 2, 3]

• Spike in Mortality Rates: A landmark study published by the National Bureau of Economic Research (NBER) tracked over 1,600 PE-acquired nursing homes and found an 11% increase in short-term patient mortality. This correlates to thousands of preventable deaths.
• Frontline Staffing Cuts: To boost margins, PE-owned facilities routinely cut clinical staffing hours. Data indicates frontline nursing assistant hours routinely drop by roughly 3% to 13%. Facilities also substitute highly trained Registered Nurses (RNs) with cheaper, less-skilled staff.
• Chemical Restraints: Due to understaffing, PE-backed nursing homes see a 50% increase in the use of antipsychotic medications to manage elderly patients rather than providing hands-on behavioral care.
• Higher Secondary Costs: Reduced daily care results in poor clinical management; residents are 11% more likely to require emergency room visits and 8.7% more likely to require full hospitalizations.

Impact on Hospitals
The financial pressures placed on acute care hospitals translate directly into degraded safety metrics for patients and heavy constraints on staff:

• Increase in Hospital-Acquired Infections: Research from institutions like Harvard and JAMA indicates that PE-acquired hospitals experience a 25% surge in hospital-acquired conditions among Medicare patients. This includes severe spikes in patient falls and central-line infections caused by inadequate floor staffing. [1, 2, 3, 4]
• Erosion of Clinical Autonomy: Physicians and nurses operating under PE management report intense corporate pressure to practice "upcoding" (billing for more expensive treatments than necessary) and to prioritize high-margin elective procedures over general public health. [1, 2]
• Closure of Vital, Unprofitable Units: To protect cash flow, PE firms frequently close down low-margin medical departments that serve vulnerable communities, heavily targeting obstetrics (labor and delivery), psychiatric wards, and emergency trauma units. [1, 2]

 

[Bob Ipock]

Borrowers are actively filing class action lawsuits against Appraisal Management Companies (AMCs). These cases challenge deceptive fee bundling and unconstitutional appraisal bias, seeking financial damages and better transparency for consumers. [1, 2, 3, 4]
The main borrower lawsuits against AMCs currently include:

• Hidden Fee and Unjust Enrichment Claims: Multiple class action lawsuits—such as Arnold v. Appraisal Nation in Florida and Timmens v. Clear Capital in California—allege that AMCs and mortgage lenders deceptively conceal. Plaintiffs argue that while borrowers pay large appraisal fees (often $450 to over $1,000), the AMCs pay the actual appraiser only a fraction and keep the rest as unearned fees. [1, 2, 3, 4]

Gee, it looks like the borrowers did care after all.

Bull****. The borrower finds out what the appraisal fee is at the time of application. Where is the HIDDEN FEE? May even have to pay the appraisal fee then just like credit report, application fee etc. They KNOW what the fee is.
They can claim otherwise but either they KNOW what the fee is or the lender is in violation of several lending laws. Want to disclose how the fee is split? Have at it but the fee will not decrease, and the appraiser will get the same fee, no more or less. It has already been shown that appraisal boards cannot set appraisal fees. Where are the "customary fees" promised years ago? If you don't like the fee, don't accept the assignment. That is what I have done for 40 years. Showing the fee split on the closing statement will change nothing. Appraisers are the biggest crybabies of all licensed people.

 

[Dublin ohio]

Borrowers are actively filing class action lawsuits against Appraisal Management Companies (AMCs). These cases challenge deceptive fee bundling and unconstitutional appraisal bias, seeking financial damages and better transparency for consumers. [1, 2, 3, 4]
The main borrower lawsuits against AMCs currently include:

• Hidden Fee and Unjust Enrichment Claims: Multiple class action lawsuits—such as Arnold v. Appraisal Nation in Florida and Timmens v. Clear Capital in California—allege that AMCs and mortgage lenders deceptively conceal. Plaintiffs argue that while borrowers pay large appraisal fees (often $450 to over $1,000), the AMCs pay the actual appraiser only a fraction and keep the rest as unearned fees. [1, 2, 3, 4]

Gee, it looks like the borrowers did care after all.

Some of those lawsuits were actually instigated by appraisers. But it had to be a consumer filing because appraisers would have no standing

 

[Bob Ipock]

I care what the appraiser gets. There is no shame in that, and I am sick of the schills trying to make appraisers feel like hypocrites for it.

At the same time, we can ALSO care about transparency. I personally care far less about the consumer overpaying because, in most cases, they did not overpay - what happened is they were not informed that a big chunk of their check would go to a middleman, AMC.

What they also were not informed about was how their order would be shopped flea market style by the AMC to the lowest bidder. Even with these lawsuits, the borrowers might not be aware of that aspect. I bet a whole lot of them would feel ripped off if they knew that.

This is the borrowers' appraisal, the valuation of their house or a home purchase; it is not shopping for sneakers on Amazon.

I have had many RE agents complain about the bad AMC appraisers they see that come into PBeach County, 2 counties away, and knew nothing about the market.

Setting real estate commission fees is ILLEGAL. The state appraisal boards found out pretty quick they could not set fees. The division of those fees is totally up to the parties involved. Go find some other appraisal work or just go get a job where you get an agreed upon salary. So from your comments anyone who works for an AMC is a bad appraiser? I have yet to see any proof of that....just talk. I have been fired from at least 30 AMCs over the years. I have my standards and I refuse to deviate from them. You think I am a schill? . Not a chance. I use my REAL NAME on here and if I **** off every AMC that is fine with me.

 

[Dublin ohio]

I’ve never had another agent comment or ask questions about appraisal fees where AMC splits are concerned, they have too many other concerns, same with the borrowers. The only ones outside of appraising that have ever asked me about AMCs are mortgage brokers. IMO the only thing that would get the borrower’s attention and the general public would be separate lines on the closing statement for the appraisal fee and the AMC fee. If closing statements read like the following : Appraiser fee $290 Clear Capital “transaction fee” $700 the borrowers and some agents would begin asking "Who the hell Clear Capital is and why do I owe them $700?" Words have meaning, “transaction fee” would be one way to cause them to ask what exactly is being transacted.

They could ask, but what good would it do.

 

[Dublin ohio]

What i want is transparency.

I'm all for transparency. But in this case, it will just result in transparency for transparency's sake