Appraisers – Your Comments Are Important

Call to Action: this must be done by Tuesday, July 7th.

The Consumer Financial Protection Bureau (CFPB) requests comments on amendments to the “Know Before You Owe” mortgage disclosure rule, which proposes to move the rule’s effective date to October 3, 2015.

Individual appraisers know it’s very important to disclose separately any add-on fees such as AMC fees or administrative costs by banks and lenders to consumers.

Recently, 23 state appraiser coalitionscoordinated and drafted a letter to the CFPB detailing the accounting discrepancy to consumers on the Loan Closing Disclosure Document as to actual appraiser fee disclosure.

Letter Submitted To CFPB By State Coalitions

Now, it’s our turn to do our part and you’re being asked to take a minute to make a personal comment to the CFPB. This is part of us having our seat at the table. Description: Comment ButtonKeep it simple, it’s about transparency to consumers.

Click here, then in the comment page site, use the blue “comment” button. You will be asked to include your name at a minimum, but can also provide your address if you so choose.

It’s just important that you make a comment.

Let’s flood them with comments from appraisers about this issue.

Once you’ve submitted your comment, please share this article with other appraisers you know or have on your e-mail group list.

Have any comments or would you like to submit content of your own? Email


About Dave Towne

Dave Towne has been an appraiser for 13 years in WA State, and is a member of three appraiser associations. Works in a 'small urban' area, surrounded by open farm lands and forested hillsides in the suburban and rural locations. Assignments vary from waterfront mcmansions to manufactured homes in MH parks, small urban sites to large acreage tracts, and everything in between, with no consistency as to assignment type. Prior experience as a writer since high school, sales of various products for 30 years prior to becoming an appraiser, and believes appraisers should get out of their basements and interact with each other frequently.

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    Retired Appraiser

    Thank God this hit the wires ON THE DAY IT EXPIRES! No coincidence there…right Appraisal Buzz?

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    The thieves that are the AMC’s, lenders, and software portal providers of the world only laugh when it takes years to propose and possibly approve the break down of appraisal fees

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    Most of my work does not officially come via traditional AMC’s, thus my appraisals reflect No AMC in the report, however this does not mean I’m collecting the full appraisal fee as it appears on the HUD-1. Even if the new regulations are approved and put in place, the injustice to the appraiser and the lie to the consumer will continue. The bulk of my work comes directly from lenders who have me on their internal preferred panels, but use software providers to create the necessary firewall between the appraiser and commissioned staff. The collected fee by these 3rd party providers in my experience can range from $30 to $100 for each assignment, however even in states when disclose is required, these fees remain in the shadows. This hidden software fee should not be confused with the delivery fees that we are also often charged (DMS Global, Appraisalport, Mercury Network etc..). Although I think it would be a step in the right direction to separate the fees, the AMC’s, lenders, and software providers can make changes in hours to benefit them, while the government takes years to think about it.

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    Last minute notification (today you can place an input). Well I did. I certainly hope that FULL MONETARY DISCLOSURE PASSES. Far too long the AMC’S have been “skimming” the appraisers rightful fee. This criminal enterprise needs to stop! Criminal enterprise? Yes it’s called extortion. They have the work (AMC’S), They pressure appraisers to take lower and lower fees. All the while charging more and more. They “SKIM” 20-45% of the “Appraisal Fee” then turn around and say that what “we pay you is customary and reasonable” If you take the assignment; that’s reasonable and “your business decision.” NOT even the loan sharks on the street charge that “vig.” Then they also charge a fee for their services to the lending institutions. Their idea of full disclosure is $550 for the appraisal minus what they are able to skim from the appraiser plus their charge to the lender. THIS NEEDS TO STOP!!!! OR AT LEAST HAVE SOME HONESTY SHOWING WHO’S ACTUALLY ROBBING THE BORROWER. LIKE I WROTE: CRIMINAL.

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    The Network of State Appraiser Organization (NSAO) (currently 23 states strong) and individual state organizations have been working this for just over a week. On Thursday of last week there were only 97 comments on the CFPB site. several were lenders. There are currently 709 comments and letters that have been transmitted; mostly from appraisal organizations and appraisers. That is a significant increase over a holiday weekend!
    It shows the importance of state appraisal collations and enforces a need for such organizations in every state! It also shows what the states can do in a short time when banded together.

    I would encourage all states with appraisal organizations to join NSAO. There is no board, no fees, and no official organization. There is representation and a lot of action geared towards improving this industry!

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