Truth or Dare

[Carnivore]

Some AMC's are cash cows. One that I am aware of has multiple income streams.

1. Appraiser fee
2. Title services fee Lawyers
3. Repair Fee's Carpenters, plumbers, electricians etc
.4, Termite exterminators
5. Surveyors
6. upcharge on couriers, fedex, UPS ect

We are their largest fee's

and more.

 

[Fernando]

Depends on market.
When appraisers are in demand, appraisers make the call on fees.
When appraisals are less, AMCs make the call on fees.

 

[George Hatch]

The AMC controls what they offer. The appraiser controls which assignments they'll accept. No forced labor or servitude involved.

 

[Tiffany Gibbons]

I voted but it is a limited choice poll that ignores the part of the secondary market of lenders who order direct (without an AMC ) - the poll centers around AMC work which is fine in and of itself, since a large volume share of GSE /secondary work goes through AMC's - the work that is left one might add, since WAIVERS are now the valuation method for a significant portion of loans-

And I got an email from a lender (addressed to all the board of realtors members) that Fannie now does waivers for 90% LTV. So, why stop at 90%?, which they won't, we know from last bailout.. Letting someone who gets paid a percentage of the loan decide the value with no appraisal license. Sure, no objective opinion of value in this market.. Makes sense. NOT.

 

[alebrewer]

And I got an email from a lender (addressed to all the board of realtors members) that Fannie now does waivers for 90% LTV. So, why stop at 90%?, which they won't, we know from last bailout.. Letting someone who gets paid a percentage of the loan decide the value with no appraisal license. Sure, no objective opinion of value in this market.. Makes sense. NOT.

Actually, the 90% is for loans were there is just Value Acceptance. For loans with Value Acceptance + PDR, the limits go to 97% in 2025.

 

[djd09]

A "customary and reasonable fee" in the context of REVAA (Residential Appraisal Management Company Association) refers to the legally mandated fair price that lenders and AMCs must pay appraisers for their services, as stipulated by federal regulations, ensuring appraisers receive a proper compensation for their work while preventing excessive fees being charged to borrowers; essentially, it's a set standard for appraisal fees that are considered appropriate for the given property and market conditions.


Key points about "customary and reasonable fee" and REVAA:

• Compliance with regulations:
  REVAA emphasizes that lenders and AMCs must adhere to the "customary and reasonable fee" requirement when compensating appraisers, aligning with federal and state banking regulations.
  
  
  
• Protecting appraisers:
  This standard is seen as a protective measure for appraisers, ensuring they receive a fair price for their services and preventing situations where they are pressured to undervalue properties for lower fees.
  
  
  
• Transaction-based determination:
  Determining a "customary and reasonable fee" is considered a transactional process, meaning it is based on the specific details of each property and market conditions, not a simple fixed number.
  
  
  
• Role of REVAA:
  REVAA actively advocates for the proper implementation of "customary and reasonable fee" standards within the appraisal industry, highlighting its importance for maintaining appraisal quality and protecting consumer interests.

 

[djd09]

JOINT TESTIMONY OF THEREAL ESTATE VALUATION ADVOCACY ASSOCIATION (REVAA)ANDCOALITION TO FACILITATE APPRAISAL INTEGRITY REFORM (FAIR)BYDON KELLY, EXECUTIVE DIRECTOR, REVAAFOR THE HEARING ON“APPRAISAL OVERSIGHT: THE REGULATORY IMPACT ONCONSUMERS AND BUSINESSES”BEFORE THE U.S. HOUSE OF REPRESENTATIVESCOMMITTEE ON FINANCIAL SERVICESSUBCOMMITTEE ON INSURANCE, HOUSING, AND COMMUNITYOPPORTUNITYJUNE 28, 2012

The first presumption permits lenders and their agents to rely upon recent rates actuallypaid for appraisal services (including rates paid by AMCs) in the relevant geographic market,adjusted as necessary to account for six other factors, such as type of property or scope of work.Although the term “customary and reasonable” was undefined in the Dodd-Frank Act, the Boardrecognized that the Dodd-Frank Act language is identical to the Department of Housing andUrban Development’s requirement obligating FHA lenders to ensure that appraisers are paid “ata rate that is customary and reasonable for appraisal services performed in the market area of theproperty being appraised.” Consistent with HUD’s approach within Mortgagee Letter 2009-28,the Board concluded that the marketplace should be “the primary determiner of the value ofappraisal services, and hence the customary and reasonable rate of compensation for feeappraisers.”The second presumption permits reliance on objective third-party information, includingfee schedules, studies and surveys prepared by independent third parties such as governmentagencies, and academic institutions and private research firms, provided they are based on recentrates paid to a representative sample of appraisers in the geographic market of the property beingappraised (but excluding compensation paid to appraisers for assignments ordered by an AMC).REVAA and FAIR believe that the Board correctly implemented Congress’ plainlanguage and intent by establishing two presumptions – one that relies on the recent ratesactually paid in the marketplace and one that relies on objective third-party fee surveys thatexclude fees charged by AMCs. There are currently very few third-party fee surveys in themarketplace, none are comprehensive enough to include all of the differences in geographicareas/markets, and they do not fully encompass all of the appraisal products offered by AMCs.The Board did not issue a “final” rule before its rulemaking authority was transferred tothe CFPB. While the interim final rule remains effective without such “finalization,” AMCs areconcerned that some appraisers may seek reconsideration by the CFPB with the intention tomandate a higher level of compensation for appraisers than is supported by current market rates.Under this scenario, consumers would be subjected to higher appraisal fees that would oftenexceed the market rate; however, consumers would not be gaining additional services in returnfor these higher fees. Instead, they would be paying higher costs for the same services, and it ismost certainly the case that these higher costs will ultimately be passed along to homeowners.Furthermore, guaranteeing a higher fee for appraisers would not ensure betterperformance, as decades of experience has shown that higher appraisal fees do not necessarilycorrespond to higher quality appraisals. Appraisers are required by USPAP to ensure thatappraisals meet minimum requirements regardless of the fee or the nature of the assignment.Prior to recent regulatory reforms, higher appraisal fees were the custom for many appraiserswho, in partnership with overzealous mortgage brokers and lenders, produced appraisal reportsthat were impacted by inappropriate influence and coercion. The resulting appraisals oftenreflected inflated values and certainly did not constitute “high quality” appraisals. The members

https://financialservices.house.gov/uploadedfiles/hhrg-112-ba04-wstate-dkelly-20120628.pdf

revaa thinks that cheap and fast will get you good...delusional...oh and by the way revaa is a proud partner of TAF

 

[Alsie35]

In our experience, the lender client basically directs the fees (meaning the same AMC will offer different fees for the same product depending on the client. That usually results in fees being good for the appraiser).

 

[Tiffany Gibbons]

Actually, the 90% is for loans were there is just Value Acceptance. For loans with Value Acceptance + PDR, the limits go to 97% in 2025.

The email says appraisal waivers beginning 01!2025 for 90% for Fannie Mae and its from a loan officer.