Strategies for raising fees

[J Grant]

Fear of failure is a fundamental for any business. Heck, it's a fundamental for any form of employment, too. Perform and compete or get fired. Pass this test or you'll fail the course.
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The AMCs have a govt perk...​

That's not how laws work. There is no law which requires lenders to use AMCs, or to engage with bundled fees. The current status was not a perk that was given to the AMCs. It was an available option which was not taken from the lenders.

Wow, the lengths you go to protect and defend government welfare for the stakeholders is incredible given your disdain for it in any other arena ! I can not spend any more time on it now as I have a report overdue. The bundled fee benefits the lenders and the AMCs; I focus on AMCs for brevity in posts.

 

[George Hatch]

"It's raining outside" is an observation. It can even be an objective observation. The comment itself is not a defense or a rationalization of the merits of rain.

You should be addressing the content itself instead of constantly making that "appeal to motive". If you want to argue the specifics of that content then lets do that. If you want to argue about my character then you should expect me to fully engage with you in kind.

Kindly note the reference to this strategy as being a fallacious mode of argument.

 

[chad hampton]

I have no problem with anyone advocating for their interest. I would prefer people advocate in good faith. What I don’t like to see is when a spokesman for five or 10 major AMC‘s walks into an appraisal board meeting, realizes that the appraisal board and staff have some issues with the AMC position, which is contradictory to the current laws, and then being told that if you try to enforce your laws, we will sue you, which was the implication.

That’s why I called them out Every chance I get. There’s no middle ground with these people, they’re going to continue to take until they put you out of business. Especially the ones which abuse their positions through intimidation. It’s not terribly difficult to intimidate a bunch of political appointments sitting on an appraisal board. Hell, 15 years ago we had an appraiser speak at our appraisal board meeting where they basically called out the board and asked them. Why is it that they only respond to threats of lawsuits?

 

[J Grant]

You should be addressing the content itself instead of constantly making that "appeal to motive". If you want to argue the specifics of that content then lets do that. If you want to argue about my character then you should expect me to fully engage with you in kind.

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I do not care about motive. I care about the outcome, which is what the government perk via the bundled fee allows the lenders to get free of cost AMC service, which gives the AMCs their huge market share, affecting the normal supply and demand dynamic. and leverabe.

I do not even do AMC work outside of one captive order firm - I just dislike the gaslighting and spin that can affect appraisers and others who might check in here by obscuring the issues.

 

[J Grant]

I have no problem with anyone advocating for their interest. I would prefer people advocate in good faith. What I don’t like to see is when a spokesman for five or 10 major AMC‘s walks into an appraisal board meeting, realizes that the appraisal board and staff have some issues with the AMC position, which is contradictory to the current laws, and then being told that if you try to enforce your laws, we will sue you, which was the implication.

That’s why I called them out Every chance I get. There’s no middle ground with these people, they’re going to continue to take until they put you out of business. Especially the ones which abuse their positions through intimidation. It’s not terribly difficult to intimidate a bunch of political appointments sitting on an appraisal board. Hell, 15 years ago we had an appraiser speak at our appraisal board meeting where they basically called out the board and asked them. Why is it that they only respond to threats of lawsuits?

The problem is they are operating within the law - it is their ability as influential donors and cronies to each other to bend the law and regulation to their will. Which, if course, puts appraisers in the terribly weak negotiation position they are in now.

 

[George Hatch]

I have no problem with anyone advocating for their interest. I would prefer people advocate in good faith. What I don’t like to see is when a spokesman for five or 10 major AMC‘s walks into an appraisal board meeting, realizes that the appraisal board and staff have some issues with the AMC position, which is contradictory to the current laws, and then being told that if you try to enforce your laws, we will sue you, which was the implication.

That’s why I called them out Every chance I get. There’s no middle ground with these people, they’re going to continue to take until they put you out of business. Especially the ones which abuse their positions through intimidation. It’s not terribly difficult to intimidate a bunch of political appointments sitting on an appraisal board. Hell, 15 years ago we had an appraiser speak at our appraisal board meeting where they basically called out the board and asked them. Why is it that they only respond to threats of lawsuits?

I daresay that every time the govt gets sued for their enforcement actions the argument being used is that that action was illegal. As is the right of the accused.

AMCs are regulated at the state level. This is the result of legislation passed at the state legislatures, not by unilateral declaration by the executive branch of state govt - which is where the state boards operate at.

You keep complaining about it without acknowledging that it would be inherently unfair to regulate any appraiser or AMC without recourse, or to regulate without representation. Nor is there anything immoral about making that observation.

 

[chad hampton]

In theory they regulated at the state level. In reality, they are not regulated.

Let’s put it another way, if DF wrote in black-and-white that one approved method of determining customary and reasonable fees is for an appraisal management company to call 100 appraisers and whichever one gives them the lowest fee is customer and reasonable. Appraisers would have to play by those rules. I don’t think anybody is showing up an appraisal board, threatening to sue them. But it doesn’t say that, and that’s not an approved method of determining it.

Maybe that’s just because working appraisers are a little more ethical than some of the other creatures in this profession.

 

[George Hatch]

I do not care about motive. I care about the outcome, which is what the government perk via the bundled fee allows the lenders to get free of cost AMC service, which gives the AMCs their huge market share, affecting the normal supply and demand dynamic. and leverabe.

I do not even do AMC work outside of one captive order firm - I just dislike the gaslighting and spin that can affect appraisers and others who might check in here by obscuring the issues.

Another day, another misread of the comment. This is what you wrote today, and is just the latest in a long history of such:

Wow, the lengths you go to protect and defend government welfare for the stakeholders is incredible given your disdain for it in any other arena !​

That quote is a direct example of the argument to motive. You are trying to paint me as an ally to the lenders and the AMCs and am commenting in their defense. Despite my repeated comments directing the blame for this situation on lender conduct. Your allegation that I'm defending them isn't even internally consistent.

Not to mention that "govt welfare for stakeholders" premise being factually untrue. And stupid, especially given how many times it's been explained to you over the years. The govt didn't give anything to anyone, including the AMCs or the lenders. What the govt did was prohibit the previously existing rights of the lenders to accept and use MB-controlled appraisals. That was a prohibition, not an entitlement.

If you want to argue that the govt should also have prohibited the lenders from engaging via AMCs then I agree; they should have. I have always agreed that the AMCs should have been likewise cut out of the appraisal engagement loop and that the lenders should have been doing 100% direct engagement all along. Whatever our other disagreements, that was never one of them. Despite your continued attacks on my loyalties and motivations.

 

[Non Sequitur]

IMO the biggest issue independent appraisers are facing is that our industry has turned corporate and isn't going back. And most independent appraisers are independent because they do not want to be corporate. At the end of the day AMC's like all corporations will never stop squeezing every penny they can.

 

[George Hatch]

In theory they regulated at the state level. In reality, they are not regulated.

Let’s put it another way, if DF wrote in black-and-white that one approved method of determining customary and reasonable fees is for an appraisal management company to call 100 appraisers and whichever one gives them the lowest fee is customer and reasonable. Appraisers would have to play by those rules. I don’t think anybody is showing up an appraisal board, threatening to sue them. But it doesn’t say that, and that’s not an approved method of determining it.

Maybe that’s just because working appraisers are a little more ethical than some of the other creatures in this profession.

What you have repeatedly criticized goes far beyond an AMC saying "this is permissible". Your criticism has been that they told the state board they were willing to take their case to court. As if they had no moral or legal right to advocate their case to that extent.

And BTW, you keep referring to "working appraisers" as being more ethical than others. So let me ask you this: If you're not spending 100% of your working hours as an appraiser then what makes you more ethical than someone who is working full time as an appraiser? What kind of reasoning is it that would lead you to believe that being self-employed as a fee appraiser is the only legitimate and ethical expression of professional appraisal practice?