Comment from Yukna, Ethan
Ethan YuknaSupportIndividual
Summary: The commenter supports the CFPB's action to require separate disclosures for appraiser fees and AMC administration fees. They argue that bundling these fees misleads consumers, suppresses appraiser pay, and harms appraisal quality by favoring the cheapest provider over the most qualified.
I support CFPB action to require clear, separate disclosure of the appraiser’s fee and any AMC administration fee on all loan disclosures. Bundling those charges into a single appraisal line item misleads consumers about what they are actually paying for and allows AMCs and lenders to retain substantial portions ($12billion, per the linked articles below) of the fee without transparent justification.
This lack of transparency has contributed to chronic fee suppression, with appraisers increasingly refusing work when fees do not reflect property complexity, required expertise, or market conditions.
https://arcc-usa.org/f/amcs-rigged-the-appraiser-supply-chain-hiding-12-billion-in-fees
https://finance.yahoo.com/news/hidden-middlemen-cost-homebuyers-12-170702387.html
https://trellis.law/ruling/cv-24-008809/timmins-lacey-vs-clearcapitalcom-inc-a/202606181285629
https://unicourt.com/case/fl-br-caseby79b2be59f2fe-2290993
This ultimately harms appraisal quality, as the cheapest appraiser and not necessarily the most qualified appraiser is hired and discourages entry into the profession. The combined fee disclosure and zero-tolerance treatment of appraisal fees should be revised so consumers see a truthful breakout and appraisers can actually operate in a free market without AMCs and Lenders fixing fees that don’t keep up with inflation.
https://appraisalfoundation.sharefile.com/share/view/s4899fb6d732a4acba6ae5d5dc21c4f9d?skipNativeCheck=true