J Grant
Elite Member
- Joined
- Dec 9, 2003
- Professional Status
- Certified Residential Appraiser
- State
- Florida
Self-employed appraisers are not locked into any single source of engagement or employment. No different than a farmer who sells their output in the market, whether hand-to-hand at a farmer's market or in lots or batches or its entirety to a wholesaler or brokerage. No different than a parts manufacturer who's output is being sold to a car manufacturer for use in their operations. No different than an accountant or atty who sells their output in the market.
Not to belabor the point, but the consumers in every one of these mortgage-related transactions are the lenders, not the borrowers. And the govt has already brought those lenders under regulation by first imposing our services on them and then imposing further limits on the form and the sourcing of these appraisals. Govt has prohibited two of the potential sources (borrower controlled or broker controlled) of these appraisals but has left direct engagement and AMC engagement in lieu of direct engagement. This entire end of the profession already exists as an unfunded tax on commerce. Insofar as mortgage lending end of the business, most of it wouldn't even exist if the govt hadn't imposed our services on these lenders - against their will.
Moreover, when the only solution to the self-employed appraiser's problem is govt intervention into the marketplace to FORCE the consumer (the lender) to pay more than they would otherwise pay in those transactions, that's the opposite of capitalism.
In any case and as it relates to self-employed entrepreneurs, free to profit on their own also means free to fail on their own. Any self-employed appraiser who doesn't want to go commando can go seek a 9-5, where they really WILL be working for a single employer and a single source of income.
The reality is that self-employed residential license fee appraisers are very limited in their employment engagements. Nobody said a single source, but the reality is a very limited set of sources for residential lender work, wrt where the large volume is . THAT is why the normal supply and demand is not possible on the AMC side of the aisle; they have enormous leverage over fees, which only worked in the appraiser's favor in the one brief period when things were very busy during a window of time post-Covid. In normally busy times, appraisers have no leverage over fees due to the extreme limitation of sources with large volumes in the AMC realm.
The regulators allowing the second version of C and R for AMC's to decide is a corrupt travesty.
Here you are protesting government intervention on behalf of appraisers, yet you think it is vine the the government has intervention or protein on behalf of stakeholders - the AMC/lender arrangement for appraisers to be compensated from the HUD fee split, with no cap on the amount or percent an AMC can take.vIf there was a cap, the lendres could vontnirly pay additionally to the AMC if they want to, since you are so concerned about protecting THEIR profit.
Nobody needs your lectures about choices and a nine-to-five job, etc. Thisis about stakeholders ecplositng a govt perk of fee split.