Request for Information Regarding Promoting Access to Mortgage Credit

[gregb]

i love it when the price fixers say do not include an invoice

US Bank's owned AMC Red Sky has recently stated to not include the appraisal fee invoice in the report.

 

[Dublin ohio]

Why has this not been corrected in 40 years? Do you really think, bankers and lawyers are going to make this happen? Do you really thing Congress casers about this issue. Tell me why, how and when and while you are at it explain why states did not enforce or even have their legislatures require it? I understand you want it to happen but the appraisal profession has a long history of promises, excuses and inability of state legislatures to fight others with more money, power and interest. You can explain it to me real slowly but this crap has been preached for probably longer than you have been an appraiser. In all this time the fee split issue has gone nowhere and has no support by those that matter.

Dude, take a chill pill. WTF are you ranting about. Did you even look to who I was responding to? I will explain this slowly: You.....................need................to.................work...................on...................your.................reading..................comprehension

 

[Bob Ipock]

I was responding to the thread. I ask the question to anyone. If this is such a big issue....why has it never been changed? The buyer knows what they are paying for the appraisal. If they want to know how it is split.....they can ask and find out.

 

[Bob Ipock]

US Bank's owned AMC Red Sky has recently stated to not include the appraisal fee invoice in the report.

Interesting issue....I have seen that before. In my opinion, the Invoice is not a part of the appraisal report. It is simply an invoice. I know that many AMCs ask it not be included. My question is why does it matter? The borrower already knows and agreed to the amount of the appraisal fee. They could request one from the closing attorney. If the attorney says they did not get one, then the invoice is not part of the appraisal. Share it with anyone you like. Perhaps not. Since the lender hired the AMC....they can tell them they always want an invoice included with thew appraisal.

 

[gregb]

Interesting issue....I have seen that before. In my opinion, the Invoice is not a part of the appraisal report.

VA requires the invoice to be the first page of the report when submitted to the VA portal.

 

[Bob Ipock]

I am sure you are right. My question is what is on the invoice is on the invoice that is part of the appraisal process or reporting? Not doubting you at all. Just looking at my invoice and wondering why it is a secret. Again, the borrower already knows and it is reported on the closing statement.

 

[J Grant]

I was responding to the thread. I ask the question to anyone. If this is such a big issue....why has it never been changed? The buyer knows what they are paying for the appraisal. If they want to know how it is split.....they can ask and find out.

No, they can not ask and find out. First of all, many borrowers do not know an AMC is used, so how can they object? Second, if an AMC asks the appraiser, the AMC engagement letter nearly always has language in it that the appraiser is not to disclose or discuss the fee.

so how could a borrower care about something they do not know. The borrowers who did manage to find out have filed multiple lawsuits. Personally, my interest is far less in addressing any harm the borrowers think was caused by non-disclosure. That is for the lawyers and courts . My main interest in the lawsuits is that they might finally get the issue out in front for the public. Banks do not care about the appraiser, but they care about bad publicity.

The lawsuits (look them up ) contains phrases such as "unjust enrichment" to the AMC because of the large chunk of the appraisal fee they keep. One lawsuit compares their fee to usury.

If the AMC's are shown to be charging fees that are unjust enrichment, at whose expense was that ? The appraisers.

you mention the past 40 years. For decades, the fee split of the bundled fee in apprasials covered small amounts for misc faxing or messengers etc. AMC's if they were used, tended to mark up the appraisal a small amount, about 10%. That changed overnight when the HVCC created incentive for lenders to use an AMC and the AMC;s siezed the moment to charge big chunks for their service, since the borrowers would not know and the lenders were okay with it.

The lender does not pay for the appraisal, the borrower does, so the lender does not save any money whether they use an AMC or not. The lender does save some money for admin by not runnign their own appraisal panel. But the sure as heck do not save the $200-$300 a report the AMC's gouge for themselves by low fee bids to find the cheapest appraiser fee.

The lender might save $50 a report if that much, since AI and computer software can QC review, assign on a rotating basis, send payment etc.

 

[TerryRohrer]

the AMC engagement letter nearly always has language in it that the appraiser is not to disclose or discuss the fee.

Another made-up fact. How could one appraiser who doesn't work for AMCs know what is "nearly always" contained in engagement letters the world over? I rarely see such verbiage.

 

[Bob Ipock]

No, they can not ask and find out. First of all, many borrowers do not know an AMC is used, so how can they object? Second, if an AMC asks the appraiser, the AMC engagement letter nearly always has language in it that the appraiser is not to disclose or discuss the fee.

so how could a borrower care about something they do not know. The borrowers who did manage to find out have filed multiple lawsuits. Personally, my interest is far less in addressing any harm the borrowers think was caused by non-disclosure. That is for the lawyers and courts . My main interest in the lawsuits is that they might finally get the issue out in front for the public. Banks do not care about the appraiser, but they care about bad publicity.

The lawsuits (look them up ) contains phrases such as "unjust enrichment" to the AMC because of the large chunk of the appraisal fee they keep. One lawsuit compares their fee to usury.

If the AMC's are shown to be charging fees that are unjust enrichment, at whose expense was that ? The appraisers.

you mention the past 40 years. For decades, the fee split of the bundled fee in apprasials covered small amounts for misc faxing or messengers etc. AMC's if they were used, tended to mark up the appraisal a small amount, about 10%. That changed overnight when the HVCC created incentive for lenders to use an AMC and the AMC;s siezed the moment to charge big chunks for their service, since the borrowers would not know and the lenders were okay with it.

The lender does not pay for the appraisal, the borrower does, so the lender does not save any money whether they use an AMC or not. The lender does save some money for admin by not runnign their own appraisal panel. But the sure as heck do not save the $200-$300 a report the AMC's gouge for themselves by low fee bids to find the cheapest appraiser fee.

The lender might save $50 a report if that much, since AI and computer software can QC review, assign on a rotating basis, send payment etc.

They can ask for the invoice at closing. The lender must comply. Do you even have a license? No J Grant listed on the ASC in Florida. Afraid to use your real name.? Must be scared of losing business to the AMCs.

 

[J Grant]

They can ask for the invoice at closing. The lender must comply. Do you even have a license? No J Grant listed on the ASC in Florida. Afraid to use your real name.? Must be scared of losing business to the AMCs.

I am a state cert registered licensed appraiser. I choose not to reveal my real name here. As do many others, because online the info can go anywhere.

One had to use their real name and present an appraisal license to register here to register for the board, when it started. I changed my name to a screen name when that became allowed for security reasons. I used my real name on the appraiser petition and in articles I gave to the press about mortgage broker pressure back in the day. A few prominent posters here include those I disagree with know my real name from private message interactions, where I respected them enough to share it with them, even if as I argue here against some of their positions.