Appraisal Service Anywhere In The United States
Why Appraisal
Management Companies are Important
The value proposition lenders
can't afford to ignore.
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 salespeople 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. Secondly, it
saves the bank money. Banks have high overhead and cannot compete with the
efficiencies AMCs offer. Finally, some banks are subscribing to vender
management because of federal 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 management
to do what they do best, make loans.
Now, back to who would object to banks outsourcing appraisals. Ironically, the
idea seems to be okay 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
villainize AMCs. Appraisers and appraisal organizations are banding together to
promote anti-AMC legislation at the state level that would require, 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 these groups are opposed to AMCs. First, many
appraisers do not like the scrutiny offered by AMCs, opting for the more relaxed
relationship and oversight offered by the lender. There is opposition to
delivery schedule timetables sometimes imposed by some AMCs. There is further
opposition to the AMC appraiser fee controls, similar to that experienced by the
medical profession regarding doctors and insurance companies.
It should be noted that not all AMCs operate in the same way nor do they have
the same policies. Just as with banks and appraisers not all AMCs are perfect.
Secondly, 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, just like many
other businesses. No management company is going to be any more willing or able
to perform services for free than an appraiser would be.
Fees charged for a standard home appraisal vary from region to region, but we
can talk about percentages. Typically, the gross margin a well-managed appraisal
management firm will earn will fall between 20 and 40 percent. That means that
the AMC will operate on about 1/3 of the fees typically charged for the
valuations delivered to lenders. Therefore, of every $100 earned by the AMC in
gross income, the appraiser earns, on average, about $70, leaving the AMC with
$30 to pay all of its expenses and provide any profit that it may make.
For this fee the AMC must:
-
Accept the appraisal order
-
Proof and edit it
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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 involve mostly labor
expenses associated with communicating with the client and vendor and processing
information. They do not reflect other overhead costs incurred by the AMC, such
as rent, utilities, janitorial, liability insurance, equipment, supplies,
advertising, legal, accounting, technology, and more. Nor do they reflect the
extensive sales and marketing or travel and entertainment expenses that come
with marketing the AMC and its fee panel appraisers to national and regional
lenders.
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 a
variety of different business relationships. 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, there can be no question that AMCs offer by far the best possible
solution to deter mortgage fraud. The true separation of the lending and
appraisal processes can only be accomplished in this manner. Separating these
processes removes most of the opportunity and temptation for participants to
become involved in collusion, which is the root of most valuation 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.
CharlieW. 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.comThis email address is being protected from
spam bots, you need Javascript enabled to view it
or through the company's Web site at
www.appraisalsanywhere.com .
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