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Alert- Twisted AMC
July 27th, 2016 9:22 PM

An AMC sent an appraiser the following email this morning: 

 ".....customary and reasonable fees are compliant under Virginia presumption that rates are based on recent rates paid to a representative sample of providers of appraisal services in the geographic market based on the fee schedules of these providers. Please complete the attached form and submit to: “

Wow are they confused about customary and reasonable feesThis is a severe twist on Virginia Regulations for customary and reasonable fee compensation to appraisers.  Virginia Law mirrors the language in the TILA. They are essentially the same.  The verbiage in the email sent to appraisers by this AMC is just WRONG!

The Virginia Real Estate Appraiser board attempted to make things easy for AMCs.  On February 23, 2016 the Virginia Real Estate Appraiser Board adopted the United States Department of Veterans Affairs’ Roanoke Regional Loan Center Appraisal and Inspection Fees Schedule as a presumption of compliance. This was a gift to the AMC’s, but I guess some just don’t want to accept it..

 The Virginia Real Estate Appraiser Board created a Guidance Document for AMCs and appraisers to help understand the law. VaCAP sent a copy of the Guidance Document  via email and US Mail to the address of record for each AMC licensed to operate in Virginia.  As AMCs did not like this clear guidance, they began to twist things around, or just ignore the parts of the legislation they did not like.

 As many were still confused, or trying to avoid paying appraisers a customary and reasonable fee, the Virginia Real Estate Appraiser Board published additional guidance on DPOR’s website. They in turn sent this additional clarification along with a copy of the original Guidance Document to each AMC and appraiser licensed to operate in Virginia.  

The Virginia Real Estate Appraiser Board has gone out of its way
 to help the AMCs. ... It boggles the mind why some refuse to accept it!

And here we are today…..  The final rules have commentary associated with them explaining each and every provision of the Dodd-Frank Act including customary and reasonable compensation to fee appraisers. Even if you don’t like the rules, we all must follow them.

 Click Here to see exactly where this AMC falls short!

Please tell us what you think.

Posted in:Customary and Reasonable fees and tagged: AMC
Posted by Virginia Coalition of Appraiser Professionals on July 27th, 2016 9:22 PMPost a Comment

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Since I am in the business of providing my opinion(s): It is my opinion that appraisers are/were extremely naive to assume any AMC would go quietly into the past - essentially giving up money to become glorified clearing houses. Especially when all any Lender of any kind needs do to be compliant is insert written SOP into the guidelines of their company ( to be enforced ) that the only folks which may communicate with an appraiser are those with no fiduciary dependence on the outcome of the report. So simple. Save every communication, no matter what you responded, that does not have the AMC registration/license number displayed in it, in a file to be presented at a board meeting? or sent to the person of the board in charge of AMC compliance.

Posted by Roger T. Easterling on July 28th, 2016 7:27 AM
It only works if the VPOR actually takes action on complaints. Based on their history that's pretty unlikely. But we don't NEED the board to act. We can...wait for it...ENFORCE C&R FEES OURSELVES. REJECT ORDERS with below market fees. How long will AMCS be able to operate WITHOUT the appraisers that they have been and continue to screw over? Weeks? Days? BB&T went to an AMC. Nobody on their panel would work for half of what we were being paid by BB&T. Within a month BB&T found another way to comply. If you want to work for the same fees we got 20 years ago go ahead and allow the AMCS to VIOLATE THE LAW. You are EQUALLY responsible when you accept below C&R fee assignments. (No it's NOT price fixing - the board as determined that the VA Fees are a MINIMUM C&R fee schedule. Charge what your fees are.)

Posted by Richard Carmichael on July 28th, 2016 12:22 PM