Comment from Anonymous

It is time to correct the errors of the past and restore transparency to the "appraisal fee" — for consumers, lenders, and appraisers alike. The fee needs to be fluid again, with the appraiser's portion clearly separated from the AMC's portion. Since 2017, when the 0% tolerance fee rule took effect, Appraisal Management Companies — which now control 70%+ of all U.S. appraisal orders — have engaged in active fee suppression. A consumer might pay $800 for an "appraisal" under their loan disclosures, while the appraiser actually performing the work receives only 40-60% of what the AMC charged. Because this fee appears on paperwork simply as "Appraisal Fee," consumers reasonably assume the appraiser receives the full amount. It should be noted that the AMC does not benefit the consumer, it benefits the lender. Our profession has seen this system abused through vendor agreements and engagement letters that prohibit appraisers from discussing their fees, require them to omit invoices from reports, and even demand revisions to strip out compensation information already included. These practices are deceptive and harmful to consumers, and they are now the subject of two active lawsuits: • Timmins v. Clear Capital, Core Valuation, and Rocket Mortgage (CV-24-008809) • Arnold v. Appraisal Nation, AMC Links, and United Wholesale Mortgage (CACE-25-019181) Yet appraisers themselves are largely unable to bring a class action, since most vendor agreements force them to sign away their litigation rights. The 0% tolerance rule has also enabled lenders to cap appraisal fees — telling an AMC "we won't pay more than $400" — sometimes formalized through service-level agreements between lender and AMC. The AMC still has to turn a profit from that $400, leaving no room for a free market where appraisal fees can keep pace with inflation. This directly conflicts with Section 129E of TILA, which requires "customary and reasonable" fees to reflect an appraiser's experience, designations, and the complexity of the property — factors most current fee schedules ignore entirely. As a result, AMCs have collected over $12 billion in fees without adequate consumer disclosure, and undermining the first presumption of compliance under Section 129E. Many AMCs continue pressuring appraisers to complete assignments for $250-350, a rate that makes it increasingly difficult for firms to hire and train new appraisers. A recent white paper from The Appraisal Foundation found that the average appraisal fee was $400 in 2010 and is $425 today. Adjusted for inflation, that 2010 fee should be roughly $630 in today's dollars — a gap that points to sustained fee suppression rather than a functioning market. The 0% tolerance rule and current disclosure requirements need to be reworked to let appraisers compete in a free market. Without that change, the profession will keep declining, putting mortgage lending itself at greater risk. A healthy, genuinely independent appraisal profession is essential — both to support responsible lending and to protect consumers from deceptive practices.