Appraisal Management Petition
Appraisal Management Petition Concerned Real Estate Appraisers, Lenders, and Consumers from across America Submit the attached petition (Which is posted on appraisalblogs.com): To: Mr. Ben Henson - Executive Director Appraisal Subcommittee (ASC) Federal Financial Institutions Examination Council email: firstname.lastname@example.org cc: Other state or federal agencies with authority in the following matter: "The ASC\'s mission is to ensure that real estate appraisers, who perform appraisals in real estate transactions that could expose the United States government to financial loss, are sufficiently trained and tested to assure competency and independent judgment according to uniform high professional standards and ethics." From the ASC website. The concern of this petition has to do with "Unearned Fees, and Unqualified Appraisal Managers" in performing real estate appraisals. We, the undersigned, represent a large number of licensed and certified real estate appraisers, lenders, and consumers in the United States, who seek your assistance in solving a problem facing us on a daily basis. Appraisal Management Companies (meaning any and all of the following: , AMC, Appraisal Servicing Companies, Appraisal Placement Companies, Appraisal Vendors, Appraisers, and Appraisal Companies) have individuals within their ranks, who, as a normal course of business, charge fees that exceed the amount that is actually paid to the licensed or certified appraiser that completes an appraisal assignment. The extra fees constitute unearned fees that are charged directly to the consumer. These companies typically do not staff or employee professionals that are qualified to accept appraisal assignments. The Appraisal Management Companies accept orders for appraisals. Then they contract this work out to independent fee appraisers and keep part of the appraisal fee that is charged to the consumer. The fees that the Appraisal Management Companies keep are in most instances titled as appraisal fees and consumers are not made aware that part of the "Appraisal Fee" is for Appraisal Management Services. The banking community has been aware of this issue for many years. Bank, Lenders, Brokers, and other Financial or Lending Related Companies that want to profit from Appraisal Fees simply form Appraisal Management Companies in order to pass on excessive fees to unknowing consumers. When Appraiser complain about these unethical practices Lenders and Appraisal Management Companies answer these complaints with the following: The withholding of business, and black listing honest appraisers. We request that action be taken to hold the lenders and Appraisal Management Companies responsible for this type of violation and provide a penalty for any person or business who engages in the practice of charging unearned or excessive fees to consumers, not disclosing Appraisal Management Fees and or calling them Appraisal Fees, and Accepting Appraisal Orders for which they have no qualification to complete. Companies or individuals that accept orders or contract to manage and or complete Appraisal Assignments should be licensed and qualified. These indeveduals or companies should either be directly licensed and qualified to complete appraisals in the state and economic location where the appraisal is to be completed or employee licensed and qualified appraisers in that state state and economic area. They should be USPAP compliant. If an indivedual or company profits from the appraisal they should be qualified to complete the same appraisal. We would like the Appraisal Laws to be amended to require any indivedual or company that completes appraisal work or contracts for appraisal work to be licensed and qualified to accept appraisal assignments in the state and community where the appraisal assignment is to be completed. The contracting of appraisal work includes appraisal management companies that contract for appraisal work and profit directly from the appraisal fee. If a company or individuals is to receive part of an appraisal fee they should be licensed and qualified to complete the very same appraisal assignment. We believe that the Appraisal management Companies have had an adverse effects on our local and national economies and that the potential for great financial loss exists. We also believe that many individuals have been adversely affected by the excess management fees that are labeled or titled as Appraisal Fees. We believe that many times these fees are paid to individuals or business that are not qualified and do not employ qualified appraisers that are USPAP complaint. We also believe that consumers are mislead into believing that they are paying for Appraisal Services and do not know that a portion of the fee is for Management Services. We believe that these kind of fees are deceptive and constitute unearned fees. We also believe that in their desire to profit from Appraisal Fees these companies and indiveduals have had an adverse affect on the American Appraisal Industry as a whole. Management companies were successfully put out of business by the surveying industry by surveyors banning togeathe and asking for new state laws that would require these management companies to be licensed to meet the minimum requirements that are needed to survey the vary same properties that they manage. This virtually required the management companies to either be licensed to complete the same work they managed or leave that business to the experts. To counter the pressure to inflate value the law makers should call for federal or state reviewers that look at a large number of the appraisal reports. Give them access to the same sales information so that they can make factual based judgments regarding value. Give these reviewers power to suspend appraisers pending a review by the state licensing board. Off set some of the workload by turning the criminal cases over to the courts where they belong. Abolish the appraisal management companies by requireing licensure. It should be a crime for any indivedual or company to manage appraisals, take a portion of the appraisal fee, or make policy regarding an appraisal report and not be licensed and qualified to complete that same report by a state licensing authority. This kind of movement will only work if appraisers work togeather. Please ask your friends to sign this petition and contact your state officials to ask for a revision of your state appraisal laws. A great article to submit to your elected official is published at the link below. You could also submit the link to this petition. Get involved. One honest voice can be louder than a crowd! Read More: http://appraiserx.com/p=29 We thank you for your cooperation and assistance.