Comment from Stanovic-Keesy, Tisha

We must 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. The TILA should allow a range in the appraiser fee and should clearly state the hold back portion that is paid to the AMC. 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. The AMC fees should actually be paid for BY 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. The system in place is abusing the appraiser profession at every step of the process; additional fees are being stripped from the appraiser through monthly portal fees, upload fees, Qc fees, technology fees, some are even charging the appraiser for a credit card fee (for the borrower!) This has quite frankly gotten out of hand. The stripping from the appraisal fees has led to appraisers no longer willing to perform reports under these conditions. Some say that there is a shortage of appraisers, when in reality, there is a shortage of appraisers willing to or able to work for such suppressed fees. The consumer is harmed when the middle man( The AMC/Lender) fails to disclose the true fee the appraiser is willing to complete the report for and is wrongly shown ALL THE FEES even the portion the AMC retains. This is not truth in lending; this is utterly deceiving the consumer. Appraisers, sustaining their professional careers, are largely unable to bring a class action suit against these practices, since most vendor agreements force them to sign away their litigation rights. As a result, AMCs have collected over $12 billion in fees from the consumer without adequate 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. If appraisers were actually paid the amount shown to the consumer for the appraisal fee training/mentoring a new appraiser would once again become feasible. 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.