When Customary Fees Become Unreasonable

[Meandering]

http://www.federalreserveconsumerhelp.gov/appraisal/appraisalComplaintForm.pdf

 

[Evincere]

http://www.federalreserveconsumerhelp.gov/appraisal/appraisalComplaintForm.pdf

The above is relevant today. How does one go about making that link a sticky reference in the forums. Instructions? Is permission needed from a moderator? I see old non relevant links and dated surveys, etc. on the various forums but nothing active and current as a direction pointer or reference.

 

[Meandering]

PM Wayne

 

[Michigan CG]

The above is relevant today. How does one go about making that link a sticky reference in the forums. Instructions? Is permission needed from a moderator? I see old non relevant links and dated surveys, etc. on the various forums but nothing active and current as a direction pointer or reference.

Create a thread properly titled with that link and I will make it a sticky.

 

[Mike Kennedy]

Then if what your saying is True, (the Appraisal Fee to the Appraiser) should Not Be Tampered with ( an AMC is not an Appraiser completing a report and therefore, should negotiate it's own compensation). Therefore, if the Lender is charging the Borrower a specific Appraisal Fee, is the Lender misleading the Borrower ?

If the fee paid by the borrower is annotated as "Appraisal Fee" and that amount is not actually paid to an Appraiser (non-employee) - it is what it is - intentional fraud.

 

[Evincere]

Create a thread properly titled with that link and I will make it a sticky.

Done. Thank you. I created a thread in the IMPROVING THE PROFESSION FORUM

http://appraisersforum.com/forums/t...-violations-of-appraiser-independence.209044/

 

[DiverMike]

The minimum fee would be the fee the lenders and GSEs and AMCs would adopt? If I was running a large AMC I would love for some agency to establish a minimum fee because that is exactly what the AMC will offer it's roster. Karl Marx said in the Communist Manifesto ( The minimum wage-fee ) is the amount required to pay the labor just enough to procreate and survive )

Thank You but No thanks I would rather keep negotiating with the lenders and AMCs because I believe I can do better than the minimum and I really don't believe in C & R because the C & R in my area is about $325.00 and the larger AMCs owned by the banks and title companies are paying as low as $250.00. Also every-time the government has got involved in our business it just gets worse.

Glen, the problem with C& R is the 'customary' part. The absolute minimum I propose ANYWHERE is $515. That's for a licensed level with under three years experience. For one with 5 to 10, I propose the minimum be $585; and for FHA work I propose $767 (ok, some rounding needed). Some AMCs require panelists be residential certified even where the work is non complex. For those I propose $685. I no longer use the term 'customary' at all. Dodd Frank had a second part re fees that they be "reasonable" and THAT is the only part I focus on now. IF you are content with $325 or even $450 rather than what you SHOULD be earning for the work you do based on erroneous philosophical perceptions no one can ever hope to change your mind. It IS your right. I respect it.

Banks already HAVE a national standard fee they pay AMCs. It is $495+- a few pennies. Many AMCs also REQUIRE one be certified. All I am saying is that in those cases the minimum must be $685; $767+- IF it is FHA.

For those still citing 65 year old perceptions of unions, go read about the fight FOR BNSF Railroad by myself and other trade unions. This is before I joined a Guild. In fact it is what opened my eyes up to the idea. I testified as a resident and an appraiser alongside union members at the L.A. and Long Beach City Councils; as well as their respective Harbor Commissions against entrenched phony environmentalists that were only trying to extort money from the railroad. You can read about it at www.mfford.blogspot.com under Southern California Inter-model Gateway (SCIG).

For your own sake as well as that of our profession, please go take another look at the proposal. All the charts in between from start up until last one are back up data. The relevant chart is the final one all the way at the end. Entire proposal should take about ten minutes to read. http://mfford.com/html/c___r_fees.htm
How about studying it and sending me suggestions to improve the proposal instead of dismissing it out of hand based on incomplete information?

 

[J Grant]

For those who imagine market forces will somehow save the day ...lobbying by corporations or banks to change regulations and govt policy to suit their interests is a part of market forces. Workers and or professionals lobbying or standing together for their interests has historically been the counter to this as part of market forces but now is being abandoned.

Some here urge appraisers as professionals to give up their their right to lobby, or join a union if they see fit, or sign a petition, or do ANYTHING for regulations that favor the appraisal profession, by using inflammatory imagery like entitlement or socialism. The corporations love you guys because you convince your fellow professionals to stand down against their own interests.

Liberty can mean can mean professionals can try to influence govt to set policies that favors our profession, just as the banks lobby to get regulations to favor their interests at the expense of ours ( which they succeeded in with Dodd Frank re writing C and R with AMC surveys vs basing it on VA fee /govg surveys as originally proposed)

 

[DiverMike]

For those who imagine market forces will somehow save the day ...lobbying by corporations or banks to change regulations and govt policy to suit their interests is a part of market forces. Workers and or professionals lobbying or standing together for their interests has historically been the counter to this as part of market forces but now is being abandoned.

Some here urge appraisers as professionals to give up their their right to lobby, or join a union if they see fit, or sign a petition, or do ANYTHING for regulations that favor the appraisal profession, by using inflammatory imagery like entitlement or socialism. The corporations love you guys because you convince your fellow professionals to stand down against their own interests.

Liberty can mean can mean professionals can try to influence govt to set policies that favors our profession, just as the banks lobby to get regulations to favor their interests at the expense of ours ( which they succeeded in with Dodd Frank re writing C and R with AMC surveys vs basing it on VA fee /govg surveys as originally proposed)

J Grant, you said it far more concisely than I could. "Liberty; Freedom, Citizenship and Patriotism" are more than mere words to me. They are both rights and obligations. As a former Marine, I have never backed away from doing what I believe is right. Even when I was a Senior Appraiser in the Treasury Department (IRS, Large Business & International Division), I could not bring myself to rewrite a report which meant a taxpayer was due a $1.45 million refund; knowing that it was the end of my career there. Refunds that large require Congressional Sub Committee approvals and we all know how fond IRS Senior Managers are of those! Sometimes we just have to bite and bullet AND fight the consequences of it. This issue is no different.

Appraisers are simply too afraid to rock the boat, so they cloak that fear in all kinds of meaningless euphemisms about being "independent; anti socialist," etc.. You clearly get it and understand the problem as well as solution. You'd be an asset in our guild. WWW.appraisersguild.org if you are interested.

 

[hastalavista]

I don't think anyone has said appraisers cannot lobby for outcomes that they believe are in their best interests. Indeed, I said be my guest.
But I equally said to not expect all appraisers to share the same vision that a national fee-structure is the solution to the problem. And,don't expect all appraisers to be neutral or passive to such ideas if they disagree with it or believe (as I do) it is detrimental in the long run.

Appraisers are simply too afraid to rock the boat, so they cloak that fear in all kinds of meaningless euphemisms about being "independent; anti socialist," etc...

No Mike, many appraisers are just too willing to compete on a low-fee/quick turn-time basis. That's the problem as I see it. Your solution does nothing to solve that problem. It artificially pegs the fee to some formula which isn't market based. It doesn't address the significant oversupply of appraisers. And it does nothing to address quality. It simply resets the pay scale based on a time-in-service formula (an as an appraiser who would benefit most from that time-in-formula, I'm 100% against it because I see superior work coming from newer appraisers vs. extremely poor-quality work coming from appraisers with more time-in than I have).

As a fellow Marine (not a former one; once a Marine, always a Marine) I admire your willingness to work for something you believe in and I wished you (and anyone else who wants to join your fight) good luck. Just don't try to imply that those who don't buy-in to what you are advocating are afraid or fearful. And be prepared to listen to criticism that a system like you propose, which rewards a higher fee based on tenure, does nothing by itself to improve the profession and is premised on the flawed concept that the longer one has been appraising, a higher fee should be awarded based on that alone.