Appraisal Service Anywhere In The United States
Why Appraisal
Management Companies Are Important
By Charlie Elliott, MAI, SRA
Lately appraisal management companies (AMCs) have been in the news. In fact few
people had heard of AMCs until recently. Perhaps that is because they are
business-to-business entities, usually not catering to the general public.
AMCs by definition are vendor management companies acting on behalf of appraisal
users. AMCs are becoming more popular among lenders, and not everyone is
pleased. Why would anyone care whether a bank outsources its appraisals?
Further, why would a bank want to farm out its appraisals?
Lenders outsource these services for three reasons. First, it helps reduce fraud
between the lender’s sales people and the appraiser, thus reducing losses while
pleasing the regulators. Fannie Mae and Freddie Mac recently implemented new
rules regarding this which some say favors outsourcing to AMCs. Second, it saves
the bank money. Banks have high overhead and cannot compete with the
efficiencies of AMCs. Finally, some banks are subscribing to vender management
because of federal Real Estate Settlement Procedures Act (RESPA) laws. RESPA, in
part, is designed to protect consumers from fee gouging. Banks must account for
closing cost fees charged to customers. It is hard for them to define and recoup
all of these costs. Collectively, these issues cause banks to outsource their
appraisals. It is easy to explain to regulators, it protects their bottom line
and it frees bank managers to do what they do best, make loans.
Now back to who would object to banks outsourcing appraisals. Ironically, it
seems to be OK with everyone except some in the appraisal profession. One may
think that all appraisers would appreciate the reduced loan-officer pressure
offered by the AMCs. This is simply not always the case. Some appraisers
villanize AMCs. Appraisers and appraisal organizations are banning together to
promote anti AMC legislation at the state level requiring among other things
that AMCs register with state appraisal boards. Among those other requirements
are large registration fees and complex regulatory demands.
Some say that requiring AMCs to register in 50 states and to comply with all
regulations will put AMCs out of business. This would appear to be the goal of
those sponsoring the legislation. There are two primary reasons for this. First
many appraisers do not like the scrutiny offered by AMCs and prefer the more
relaxed relationship and oversight of the lender. There is opposition to
delivery schedule timetables sometimes imposed by some AMCs. There is further
opposition to the AMC appraiser-fee controls, as we have experienced by the
medical profession with doctors. It should be noted that not all AMCs operate
the same, nor do they have the same policies. Just as with banks and appraisers,
not all AMCs are perfect. Second, in spite of what many appraisers say about
wanting independence, some are willing to trade this for the cozy relationship
they enjoy with lenders, who select them to do work.
Appraisers have the option of either doing AMC work or declining it. Appraisal
management is part of our free enterprise system.
There are misconceptions about fees collected and paid by AMCs. I have heard
appraisers say that AMCs collect full fees and pay out only a portion of the fee
to the appraiser. AMCs do operate on a gross margin of profit as any business,
and no management company is going to be any more willing or able to perform
services for free than appraisers would be.
Fees vary, but let’s say that the average fee charged by an appraisal management
company is $360 for a standard home appraisal. Gross margins before expenses,
which AMCs typically earn, range between 30 percent and 40 percent of the fee
charged, or let’s say about 1/3 of the fees charged. Therefore, the AMC will pay
the appraiser on average about $240, leaving the AMC $120 to pay all of its
expenses and to cover any profit that it may make. For this fee, the AMC must
accept the order, proof and edit it, select the best appraiser, negotiate a fee,
place the order, monitor the progress, take product delivery, review the
appraisal, supervise corrections, ship the appraisal, field any client
questions, bill the client, pay the appraiser, collect client fees and securely
store the product for five years. These functions of the process involve mostly
labor. They do not reflect other overhead cost experienced by the AMC, such as
rent, utilities, janitorial, liability insurance, equipment, supplies,
advertising and technology.
There will be varying opinions on AMCs and their role in the vender management
process. It is not suggested that every lender should use an AMC or that every
appraiser should work for one. Lenders and appraisers have the right to pursue
any business relationships they choose. They should be allowed to exercise this
right without disruption from those who do not have a dog in the fight. AMC
registration in each state is simply a burdensome minefield and is perceived by
some as a violation of free trade. Any AMC regulation should be at the federal
level, only one fee should be charged and rules should be uniform across the
country.
Finally, it is without question that AMCs offer by far the best possible
solution to deter mortgage fraud. The true separation of the lending and the
appraisal process can only be accomplished in this manner. The process removes
most of the opportunity and temptation for participants to become involved in
collusion, which is the root of most fraud cases. AMCs also represent our best
option for holding down mortgage fee cost to consumers and encouraging
competition among appraisers. In these trying economic times given the mortgage
crisis and the economic meltdown, AMCs represent a bright ray of positive
direction for the mortgage industry.
Charlie W. Elliott Jr., MAI, SRA, is president of Elliott & Company Appraisers,
a national real estate appraisal company. He can be reached at (800) 854-5889,
charlie@elliottco.com or through the
company’s Web site at
www.appraisalsanywhere.com.
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