The Appraiser Shortage Myth Part 43

[hastalavista]

It is listed right on the cfpb website and nothing has changed as preseumption 1 does not require the exclusion of AMC fees.

(my bold)

Exactly.

 

[hastalavista]

Thank you for posting it In post 469, TMD

I thank him as well. Because I don't know how appraisers can come up with workable solutions to the challenges we see (even if we don't all agree on the same problems) if we don't understand what the regulations actually state, allow, require, and exempt?

 

[timd354]

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.
So compete in the lender market then...why are you complaining if you can get all of the work that you need at your fee?

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.
Whatever government protection that you think AMC's enjoy is the result of many appraisers clamoring for AMC regulation. BTW, I think that any business is entitled to make as much as the market will bear and that applies both to appraisers and AMCs. It is quite funny to listen to appraisers bellyache about AMC profits, yet they are bellyaching only because they want more profits from themselves. If you want to make more money, find better clients who reuire complex work (i.e., litigation related work ) and charge more for that work.

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.

I don't care if you lower your fee or not, but your incessant whining regarding fees and insistence that you be paid some sort of government mandated fee is absurd

 

[timd354]

I thank him as well. Because I don't know how appraisers can come up with workable solutions to the challenges we see (even if we don't all agree on the same problems) if we don't understand what the regulations actually state, allow, require, and exempt?

It is hard to figure, but it is clear that some people simply are or unable or unwilling to accept those regulations that don't say what they want those regulations to say....In fact Dennis, I wonder where your good friend from PA is lately with her absurd interpretations of these regulations.

 

[Eli]

See who starves out first. That AG in LA may starve a few out.

 

[djd09]

Hiding behind the regs. Classic.

Where is the fee data? oh ok. Hook, line, and sinker.

 

[TRESinc]

But if you refuse to answer, then I say you have no right to ever say anything derogatory about another appraiser on this forum ever again, or anything related to appraisal for that matter. YOUR credibility will be zero. I'll give you a hint, the question is relevant to this thread.

to quote my late grandfather - who died and made you king sh|t?

 

[J Grant]

What has changed is state boards to enforce, and they have latitude about that and which presumption to rely on- its just getting started at the state levels with results made public- even if contested the fact that the decisions and results of sate boards are out there seems to be making AMCs and some lenders uncomfortable, (which may be leading to recent trend of more lenders moving away from AMC's and ordering direct )

To that end AMC's seem ultra sensitive now about the issues and won't publish a fee list as they used to, instead saying they pay appraisers "their fee",(what a confidence that only the lower of "their" fee appraisers get the work) .

A state board examining fees can clearly see if lender and VA and non AMC work differs sharply and consistently from what an AMC pays. A shame it has to come to such epic battle proportions fought out state by state but at least more of it will be out in the open.

 

[timd354]

What has changed is state boards to enforce, and they have latitude about that and which presumption to rely on

No, that is not what the law states. The law states that the AMC is entitled to a presumption of compliance if they meet either presumption 1 or the alternative presumption of compliance (presumption 2)...the board cannot pick and choose which part of the law that they like and wish to enforce.

That being said, I have no doubt that a few rogue state boards will try to ignore the law - in fact, one already has.

 

[DWiley]

. 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

Actually, a better comparison is to the way the real estate market operated before the introduction of the modern MLS system. Buyers only had data on a limited segment of the market. Modern MLS systems changed that, and now market participants have access to far more data. And now we have even more data with Zillow, Trulia, etc.

FCR says that AMCs pool the labor, but the labor still operates as individual companies contracting with the AMCs. What is being pooled is the information about the labor. That information includes service times, quality, how those compare to others in the same market, and, yes, fees within the market area.

Selling services in a non-AMC market is like selling a home in an area without MLS or some other such system. There is far less data for a buyer to use in making a purchase decision.