• Welcome to AppraisersForum.com, the premier online  community for the discussion of real estate appraisal. Register a free account to be able to post and unlock additional forums and features.

The Appraiser Shortage Myth Part 43

Status
Not open for further replies.
That particular provision applies to surveys. It does not apply to studies of actual fees paid. Can't just read the parts you like. :)

It is funny how people want to argue both ways on this. On the one hand they say that AMCs have too big a share of the market, yet they also want to argue that even though over half the business goes through AMCs, those fees should not be used to determine market rates (C&R). :) If somewhere between 50% and 80% of transaction are conducted a certain way, then what should establish the market rates for those transactions? The 50% to 80% or the remainder? I know how you will answer, but what would your answer be if the question was about real estate prices rather than appraiser fees? :)

I'll give you credit for being upfront about it here. It's about your company and similar AMC's wanting to establish your own low payout rates to bring down C and R, thus making you always in compliance.

Of course cost plus would eliminate all this nonsense. The lenders who affiliate/own stock in low pay AMC's are as loathe to implement cost plus as the AMCs for good reason. If a lender, or AMC has to publish a list of uniform appraisal fees they pay in an area ( which is the best way to implement cost plus) the list is out there for all to see, or be compared to the C and R of what other lenders and VA pay. Thus they can blame the low fees they pay now as only going along with what an appraiser quotes ( we pay THEIR fee)! , or supply and demand, or appraiser behavior, etc. Of course cost plus would trim down the AMC fee down in most cases, which is the real reason for the resistance..
 
Denis, that is from 2010 !
 
TMD -]Your fee apparently is not competitive with your peers in your market, but yet you still want someone to use you and pay you more than they need to pay to obtain an acceptable appraisal because...exactly why should that happen?

My fees are competitive outside of non AMC market, as I get plenty of work from direct lenders who pay the fee I charge. (or their uniform fee is similar, take your pick) I certainly am aware of the fact that any time I want to lower my fees, I can compete in the AMC market.

I guess that you think that you are entitled to your fee even if that fee is higher than what other appraisers in your market charge or you think that you are a better appraiser than practically everyone else in your market, but that is what most appraisers think and is just wishful thinking in most cases.

You just wrote a fantasy about what you think I think! How funny! The reality is my fee is not higher than what other appraisers in my market area charge for non AMC work. In fact, it was lower on one panel I signed up for, so they paid me MORE (which is how C and R works).

You love to throw around the hot button word entitlement- why do you think the AMC is entitled to take as much as they can from the borrower paid $ amount ( A rhetorical question) . You chastise appraisers for wanting govt protection, yet the AMC interests are the ones enjoying the large share of govt protection, and they actively seek to keep and enlarge that share with lobbying and other efforts.

You have been out-competed in the market place for SL's business and now you want the government to come in and fix it for you by forcing users of appraisal services to pay above market fees or mandate some sort of mandatory rotation so you can get your piece of the pie without having to out-compete your peers.


Since the govt regulates so much around appraisal ordering and fees for res lending work, , yes I think they should step in to correct the imbalance created with the flaw in the firewall system. The flaw is combining it with a for profit conflict of interest around appraisal selection and the blended fee on HUD lacking any distinction between the value of the different services it covers, primary service ( appraisal) secondary service (management. ) The lender and by extension borrower need an appraisal for the mortgage transaction. The lender, and thus the borrower, do not need an AMC doing the management aspect for a mortgage transaction.

You are free to disagree, we disagree. To date, no I will not lower my fee to where it needs to go to get SL work, of course I could do that any time I want . The term peers in USPAP references professional, competence and experiences in similar assignments, the word peers does not relate to what appraisers charge. People charging different rates may or may consider each other peers.
 
It is late and I could take your response line by line and respond, but again, it is late.

You asked an obtuse question and hopefully didn't really expect a response. Your question was never intended to have a response.

You can "call out" Danny for anything you want but that does not make you "correct" or mean you have any reasonable expectation of a response. He works for an AMC, he gives his views and sometimes he posts the "company line".

Danny does not "owe you" a response. He participates in this forum because he wants to. I can post something that you do not like and you can ask a question of me and I don't "owe you" a response either.

As to your claim that he has accused appraisers of being delusional he is correct. Some are. We are self-employed people and have to react to the market. In some areas there is an over-supply of appraisers and therefore fees will be low. It is basic economics we learned in the first year of college. AMCs are in the business of making money (just like all of us do) and they will do what they can to do that. I don't like some the tactics they use but it is what it is.

His time management argument is the "company line" selling his AMC's product. I am not interested and if you are not interested don't work for his company. The idea that most of us need better time management is garbage.

Our business can be ugly. Guess what? All businesses can be ugly. Supply and demand is a part of EVERY SINGLE BUSINESS. Danny's company can do what they can because of supply and demand but they have to adapt to regional or local situations as he has posted. Danny defends his company's 48-hour after inspection time very poorly multiple times but I would guess his company looks away in COW states if they are smart. He has to defend this "requirement", it is the company line.

Danny does own what he does. He has never been secretive about it. Does he sugar-coat? That is up for interpretation. He is part of an AMC. Take it for what it is worth.

The personal attacks on him are not warranted.

I doubt I would ever take work from his company but folks should at least appreciate that he posts here as he gives insight to the workings of one aspect of the AMC model.

So first off, thank you for your appropriate response - I truly appreciate that. And I suppose you are right, I did get a little personal at the end there. I suppose that can happen when I feel personally insulted. Something I have found interesting here, is that DW sure does have a lot of friends on tis forum. It has been amazing to read how many come to his defense instead of letting him stand up for himself and his views. And while I can give that some credit, its not enough for me to let the things that have been said, and just as importantly the way they have been said, in the context they are said, slide.

As far as all of the other stuff you have said about how things get said or conversed on this forum, I agree those things apply to me, though I would point out they apply to everyone else too (being owed, expectations, opinions, etc.). For the record, my expectations of others are low, but that is not going to stop me from engaging - the back and forth is why I come here in the first place and there is nothing I value more than learning something new (which usually equates to me being wrong). So on that note, if I have crossed the line of making it a bit too personal, on that score I apologize to you, this forum and DW. For all other counts, I make no apologies.

The biggest problem I have with what DW is saying on this thread, and he has finally addressed that specifically to me (thank you DW and Ill get to that next), is the lack of, or at the very least failing to acknowledge, the context when defining market value. We are appraisers and defining the context of market value is essential, as we all know. DW is trying to contend that the AMC behavior of pooling labor and forcing appraisers to compete against each other on a mass scale results in market value. He keeps ignoring the true context of that market and clearly wants to convince us that it is not only customary, but reasonable. I contend that reasonable is subjective, and will voice my opinion further on the matter to him directly and see where that goes.

Thanks again for responding in a thoughtful and contextual manner.
 
SL sells hamburgers to lenders for $10. The appraisal panel consists of McDoubles ($1), Jr Bacon Cheeseburgers ($2) and Five Guys Doubles ($6).

More profit in the McDoubles....I wonder what the client thinks about that....."The fee is set by the appraiser"...we will never know the "appraiser set fee' number unless required by the state.....
 
  • Like
Reactions: DTB
Face it. C & R is a joke, it always was. It is simply that you have to negotiate from a position of weakness since you are offered a limited number of jobs and they are eblasting every appraiser within 100 miles...it's like fishing with a cane pole v. fishing with a stick of dynamite.
 
It does not state what you think/want.[/
You're right. :ohmy:
Have you seen the most current one?
It is listed right on the cfpb website and nothing has changed as preseumption 1 does not require the exclusion of AMC fees. Only fee studies done to meet the alternative presumption of compliance (presumption 2) require the exclusion of AMC fees
https://www.consumerfinance.gov/eregulations/1026-42/2013-30108_20150718#1026-42-a

Customary and reasonable compensation

  1. Requirement to provide customary and reasonable compensation to fee appraisers.In any covered transaction, the creditor and its agents shall compensate a fee appraiser for performing appraisal services at a rate that is customary and reasonable for comparable appraisal services performed in the geographic market of the property being appraised. For purposes of paragraph (f) of this section, “agents” of the creditor do not include any fee appraiser as defined in paragraph (f)(4)(i) of this section.
  2. Presumption of compliance.A creditor and its agents shall be presumed to comply with paragraph (f)(1) of this section if:
    1. The creditor or its agents compensate the fee appraiser in an amount that is reasonably related to recent rates paid for comparable appraisal services performed in the geographic market of the property being appraised. In determining this amount, a creditor or its agents shall review the factors below and make any adjustments to recent rates paid in the relevant geographic market necessary to ensure that the amount of compensation is reasonable:
      1. The type of property,
      2. The scope of work,
      3. The time in which the appraisal services are required to be performed,
      4. Fee appraiser qualifications,
      5. Fee appraiser experience and professional record, and
      6. Fee appraiser work quality; and
    2. The creditor and its agents do not engage in any anticompetitive acts in violation of state or Federal law that affect the compensation paid to fee appraisers, including:
      1. Entering into any contracts or engaging in any conspiracies to restrain trade through methods such as price fixing or market allocation, as prohibited under section 1 of the Sherman Antitrust Act, 15 U.S.C. 1, or any other relevant antitrust laws; or
      2. Engaging in any acts of monopolization such as restricting any person from entering the relevant geographic market or causing any person to leave the relevant geographic market, as prohibited under section 2 of the Sherman Antitrust Act, 15 U.S.C. 2, or any other relevant antitrust laws.

  3. Alternative presumption of compliance.A creditor and its agents shall be presumed to comply with paragraph (f)(1) of this section if the creditor or its agents determine the amount of compensation paid to the fee appraiser by relying on information about rates that:

    1. Is based on objective third-party information, including fee schedules, studies, and surveys prepared by independent third parties such as government agencies, academic institutions, and private research firms;
    2. Is based on recent rates paid to a representative sample of providers of appraisal services in the geographic market of the property being appraised or the fee schedules of those providers; and

    3. In the case of information based on fee schedules, studies, and surveys, such fee schedules, studies, or surveys, or the information derived therefrom, excludes compensation paid to fee appraisers for appraisals ordered by appraisal management companies, as defined in paragraph (f)(4)(iii) of this section.

 
. DW is trying to contend that the AMC behavior of pooling labor and forcing appraisers to compete against each other on a mass scale results in market value.

More like liquidation value lol ...

Thank you for posting it In post 469, TMD
 
Status
Not open for further replies.
Find a Real Estate Appraiser - Enter Zip Code

Copyright © 2000-, AppraisersForum.com, All Rights Reserved
AppraisersForum.com is proudly hosted by the folks at
AppraiserSites.com
Back
Top