rssRules to Regulate Home Appraisals Stymie Industry, Home Buyers
Wednesday, August 05, 2009 at 6:00 am
- 47 Comments
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Anyone who’s ever purchased a home knows that the appraisal is a key component. Buyers rely on the appraisal to ensure that they’re not overpaying for their prospective home, while lenders need to make sure they’re not lending more than the home is worth.
But these days, getting an appraisal can be trickier than ever.
Illustration by: Matt Mahurin
As of May 1, new legislation called the Home Valuation Code of Conduct makes getting an appraisal costlier and more time-consuming for would-be buyers to procure — and the added time can even prevent purchasers from getting the best possible mortgage on their new home. This creates a stumbling block for home buyers at a time when the market can ill-afford to discourage buyers. And that’s not even the worst problem.
Advocates for the appraisal industry say that a move towards less-qualified appraisers prompted largely by the requirements of the new regulations mean that already depressed home prices are being undervalued even further. The problem has gotten so severe that even real estate trade groups that called for enhanced oversight in the first place are now working to dismantle its key provisions. And the controversy, some say, also shows how difficult it can be to reform even some of the most egregious practices blamed for creating the housing bubble in the first place.
“Initially we were in full support of the concept because we have for several years now been trying to get the powers that be to recognize that there were significant pressures placed on appraisers to meet certain values,” said Leslie Sellers, president-elect of the Appraisal Institute, a voluntary membership organization that certifies appraisers. Sellers added, “The unintended consequences have created havoc.”
Reforming the appraisal process goes back to earlier this decade, as home prices around the country inflated to what turned out to be unsustainable levels. Appraisers complained on blogs and industry message boards of being pressured by mortgage brokers, lenders and even builders to “hit a number,” in industry parlance, meaning the other party wanted them to appraise the home at a certain amount regardless of what it was actually worth. Appraisers risked being blacklisted if they stuck to their guns. “We know that it went on and we know just about everybody was involved to some extent,” said Marc Savitt, the National Association of Mortgage Banker’s immediate past president and chief point person during the first half of 2009 as the industry geared up for the rollout of the legislation.
Critics of the new regulations say problems started right at the beginning. Instead of being developed at the behest of and in collaboration with appraisers, HVCC was borne out of a settlement deal between the New York Attorney General’s office and Fannie Mae and Freddie Mac, the two giant government-sponsored entities that together make up the engine of the mortgage business. Why the GSEs were targeted by the state of New York is still unclear. The Center for Public Integrity has filed FOIA requests for correspondence between the two entities and the Attorney General to try and find out. Most players in the industry assume that Fannie and Freddie came under fire for buying and selling loans backed by inflated appraisals without verifying if the values were legitimate.
Prior to May 1, many appraisals were ordered by mortgage brokers. It was a convenient, if sometimes overly cozy, relationship. Brokers would go to local appraisers in the hopes of getting a valuation that would reflect a deep knowledge of the town, neighborhood and even street on which the property was located. Some lenders ordered appraisals directly, often through middlemen called appraisal management companies. The HVCC shook up the status quo by forbidding brokers to order appraisals; instead, that task now falls to lenders. Lenders, many of them big, national banks, have turned to appraisal management companies to manage the ordering process rather than try to forge individual relationships with literally thousands of individual appraisers across the country.
As a result, these appraisers have had to align themselves with the AMCs or run the very real risk of going out of business. Although the HVCC currently is only scheduled to be in place for 18 months, once banks create the new AMC-based infrastructure to manage appraisal ordering, it’s likely that individual appraisers will be left out of the loop for good.
The appraisers, not surprisingly, aren’t happy.
First of all, they point out, pressure to “hit a number” came not just from brokers but from lenders and even appraisal management companies as well. The HVCC in its current structure only addresses part of the problem while concentrating power in the hands of the AMCs. The other problem is that AMCs themselves aren’t exactly blameless. In fact, the New York AG’s initial investigation included not only the GSEs and mortgage lender Washington Mutual, but an AMC, too, a firm called eAppraiser.
“This is the bizarre part,” said Brian Davis, a Bloomington, Ill.-based appraiser and founder of the blog Appraisal Scoop. “The original problem was pressuring of appraisers by an appraisal management company, and this puts AMCs in the catbird seat.”
Davis isn’t alone in his view. “AMCs have a lot of money to gain in this. Even if the HVCC is overturned at some point a lot of appraisers are going to be out of business,” said Joseph Eaton, staff writer at the Center for Public Integrity. “It puts the AMCs in a great situation.”
Given that one of the corporations is embroiled in the initial scandal, many in the real estate industry question why the resulting legislation assigns such a major role to these entities.
“More qualified appraisers are dropping out, and using lower appraisals creates lower value down the line,” said Leslie Sellers of the Appraisal Institute. To cover their overhead, Sellers says AMCs are paying appraisers less but charging lenders — who pass the cost along to buyers — more per appraisal. As a result, less-experienced appraisers are taking on the lion’s share of the work, while appraisers who demand a higher fee turn down the AMCs’ offers for more lucrative work.
In addition, these novice appraisers may be valuing homes in areas outside their scope of expertise. Particularly in densely populated areas, even an appraiser who knows one neighborhood well could be completely unfamiliar with another neighborhood or town a short drive away. Industry insiders like the Appraisal Institute’s Sellers also says AMCs demand turnarounds of as little as 24 hours, leaving appraisers little time to do research on unfamiliar locations.
This combination of factors will lead to an artificial depression of home prices beyond the trough created by the subprime crash, Sellers says. Whereas an experienced appraiser would know his or her market well enough to not include foreclosures and short sales when evaluating comparable sales, someone who drove in for the first and only time that day would have no way of discerning these small but crucial details. While no one in the industry denies that homes were valued beyond what they were truly worth during the go-go years, appraising them at fire-sale prices only adds to the market’s pain.
Appraisers’ harsh words for the program were echoed by the National Association of Mortgage Bankers. “Although the HVCC doesn’t mention AMCs, it’s kind of a back door promotion of the AMCs. AMCs are unregulated, and they’re controlling the entire housing market,” charged NAMB’s Marc Savitt.
Even more worrisome, the second part of the HVCC, the creation of an enforcement entity to be called the Independent Valuation Protection Institute that would field complaints of appraisal coercion, has been placed on the back burner due to budgetary concerns. “We need to put some real teeth into this thing,” Savitt said.
Compounding this lack of oversight, a lack of regulation in the AMC industry means that even appraisers who actually are disciplined for artificially inflating home prices can get right back into the business by setting up shop as an appraisal management company and hiring others to do the work for them.
Industry watchdogs point to yet another way the HVCC open the door to impropriety: banks themselves are allowed to own up to 20 percent of the appraisal management companies who do work for them. While Jeff Schurman, executive director of the Title/Appraisal Vendor Management Association, an industry trade group that counts AMCs among its member base, calls potential conflicts of interest a “non-issue,” others voice skepticism that an AMC wouldn’t feel pressure to deliver for its parent company.
Even the companies one would think would be jumping for joy — the AMCs themselves — are decidedly lukewarm about the HVCC. “Our comments were very critical for a couple of reasons,” says Jeff Schurman of TAVMA. A big complaint TAVMA shares with most other real estate industry groups is the issue of portability. Previously, a would-be home buyer could get an appraisal through their broker, then shop around to get the best deal on a mortgage. Now, since the lender is in charge of ordering the appraisal, the home buyer can’t use it if they decide they can get a better deal from another bank. Instead, they’ll have to pay for a second appraisal ordered by that lender. This not only means an added cost for buyers, but it’s a potential disincentive for lenders to compete on rates, since buyers will be reluctant to switch lenders after they’ve already spent as much as $750 for an appraisal.
With all of these issues coming to the surface, perhaps it’s no surprise that the industry is battling hard to alter or outright scrap the HVCC. The current president of the Appraisal Institute has been meeting with representative of Fannie Mae and Freddie Mac to try and tweak the verbiage and the requirements contained in the regulation, while a bipartisan bill in the House of Representatives calls for an 18-month moratorium on the regulation. While almost no one in the industry denies the need for oversight in the appraisal process, the HVCC places significant strain on an already damaged housing market.
Martha C. White is a freelance journalist in New York.
47 Comments
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Comment posted August 5, 2009 @ 2:48 pm
Your report is very slanted and does not give an accurate picture of the greater landscape that the ordinary appraiser works in. As a state certified residential appraiser with 12 years experience, I have worked directly with major banks, local banks, mortgage brokers as well as the AMC's. Each has their pluses / minuses (except the mortgage brokers). By far and away, the mortgage brokers are the worst to work for. There income was based directly from the mortgage they were trying to originate. If you didn't hit their number several times, you were black listed. Getting paid was also a significant problem. AMC's are at the other end of the spectrum. The major problem is that they take a substantial cut of the appraisal fee, more than I think is proper, but I have experienced almost no pressure to hit numbers. Most have their systems that appraisers are required to adapt to and some are even beginning to charge to use their systems. Major Banks were great to work for as you usually had some bank specific requirements. Local banks are normally great to work for but there are problems with cliques and some bank specific requirements that were nonsensical.
Real estate appraisers are normally very independent types. We tend to bitch just to bitch if we do not have real problems. Borrowers need us but usually do not understand how we do our work. Your statement that borrowers can not use a report that they had done previously before they found their lender is causing extra time and cost is not true. In NC, borrowers have not been able to do this for a number of years. While the HVCC is not any where near perfect, separating ordering appraisals from the person who is making the loan is good lending policy. That Fannie / Freddie were asked in on the process, they are the ones who would, in most cases, eventually buy the mortgages so it was not outlandish that they were part of the development process.
The statement that inexperienced appraisers are the only ones who will work for the AMC’s is just not true. As for driving us older guys out of business, if you look at the stats, fewer people are getting into fee appraising, appraiser liability issues are growing, fewer established appraisers are willing to take on trainees and the number of active appraisers is falling. This was happening before the HVCC was introduced. We are the only professionals who refuse to organize into a single group to make our case to the powers that be. So we tend to get dumped on and so we just bitch
Comment posted August 5, 2009 @ 2:48 pm
Your report is very slanted and does not give an accurate picture of the greater landscape that the ordinary appraiser works in. As a state certified residential appraiser with 12 years experience, I have worked directly with major banks, local banks, mortgage brokers as well as the AMC's. Each has their pluses / minuses (except the mortgage brokers). By far and away, the mortgage brokers are the worst to work for. There income was based directly from the mortgage they were trying to originate. If you didn't hit their number several times, you were black listed. Getting paid was also a significant problem. AMC's are at the other end of the spectrum. The major problem is that they take a substantial cut of the appraisal fee, more than I think is proper, but I have experienced almost no pressure to hit numbers. Most have their systems that appraisers are required to adapt to and some are even beginning to charge to use their systems. Major Banks were great to work for as you usually had some bank specific requirements. Local banks are normally great to work for but there are problems with cliques and some bank specific requirements that were nonsensical.
Real estate appraisers are normally very independent types. We tend to bitch just to bitch if we do not have real problems. Borrowers need us but usually do not understand how we do our work. Your statement that borrowers can not use a report that they had done previously before they found their lender is causing extra time and cost is not true. In NC, borrowers have not been able to do this for a number of years. While the HVCC is not any where near perfect, separating ordering appraisals from the person who is making the loan is good lending policy. That Fannie / Freddie were asked in on the process, they are the ones who would, in most cases, eventually buy the mortgages so it was not outlandish that they were part of the development process.
The statement that inexperienced appraisers are the only ones who will work for the AMC’s is just not true. As for driving us older guys out of business, if you look at the stats, fewer people are getting into fee appraising, appraiser liability issues are growing, fewer established appraisers are willing to take on trainees and the number of active appraisers is falling. This was happening before the HVCC was introduced. We are the only professionals who refuse to organize into a single group to make our case to the powers that be. So we tend to get dumped on and so we just bitch
Comment posted August 5, 2009 @ 2:49 pm
Your report is very slanted and does not give an accurate picture of the greater landscape that the ordinary appraiser works in. As a state certified residential appraiser with 12 years experience, I have worked directly with major banks, local banks, mortgage brokers as well as the AMC's. Each has their pluses / minuses (except the mortgage brokers). By far and away, the mortgage brokers are the worst to work for. There income was based directly from the mortgage they were trying to originate. If you didn't hit their number several times, you were black listed. Getting paid was also a significant problem. AMC's are at the other end of the spectrum. The major problem is that they take a substantial cut of the appraisal fee, more than I think is proper, but I have experienced almost no pressure to hit numbers. Most have their systems that appraisers are required to adapt to and some are even beginning to charge to use their systems. Major Banks were great to work for as you usually had some bank specific requirements. Local banks are normally great to work for but there are problems with cliques and some bank specific requirements that were nonsensical.
Real estate appraisers are normally very independent types. We tend to bitch just to bitch if we do not have real problems. Borrowers need us but usually do not understand how we do our work. Your statement that borrowers can not use a report that they had done previously before they found their lender is causing extra time and cost is not true. In NC, borrowers have not been able to do this for a number of years. While the HVCC is not any where near perfect, separating ordering appraisals from the person who is making the loan is good lending policy. That Fannie / Freddie were asked in on the process, they are the ones who would, in most cases, eventually buy the mortgages so it was not outlandish that they were part of the development process.
The statement that inexperienced appraisers are the only ones who will work for the AMC’s is just not true. As for driving us older guys out of business, if you look at the stats, fewer people are getting into fee appraising, appraiser liability issues are growing, fewer established appraisers are willing to take on trainees and the number of active appraisers is falling. This was happening before the HVCC was introduced. We are the only professionals who refuse to organize into a single group to make our case to the powers that be. So we tend to get dumped on and so we just bitch
Comment posted August 5, 2009 @ 3:36 pm
Few industries deserve to be stymied more than the real estate industry.
Comment posted August 5, 2009 @ 3:36 pm
Few industries deserve to be stymied more than the real estate industry.
Comment posted August 5, 2009 @ 3:52 pm
David B. needs to be in the business for another 12 years obviously. He appears to be one of the appraisers who cannot deal with the pressure from clients. Brokers are tough to deal with, yes, but there are more who look to you to protect them and their borrower from a bad deal than those who do not. you just haven't found them because you are willing to do the high volume/low fee AMC work. It probably takes you two weeks to turn a file around too. In NC, client pressure shouldn't matter anyways because we have one of the most active state appraisal boards in the country. If you do a bad appraisal, sooner or later one will show up at the state board in the form of a complaint. AMC's are bad. The HVCC is bad. AMC's generate no money on their own, but instead inflate the appraisal fee so they can skim their fee off of it or they find the cheapest appraiser so they have the highest profit margin. If you work for them, you know that is the case. Just saw an appraisal done in NC coastal area by an AMC appraiser from Illinois. Desktop, no inspection. Guess who has a copy of that appraisal now. Any appraisers who are standing by the HVCC as a good thing are the ones doing the AMC work and have high volume right now because they can't get regular work from regular clients.
Comment posted August 5, 2009 @ 4:13 pm
I'm a fan of my AMC. I do wish the HVCC mandated competition, that is, that no lender could require an appraisal from any specific AMC. That would level the playing field significantly and get rid of the large majority of non-market problems people are having with appraisals.
Comment posted August 6, 2009 @ 5:06 am
David B. As an fellow appraiser I whoelhearatedly agree. What a slanted report and by the way…what in the world is up with the Appraisal Institute? I am beginning to think they may be corrput also.
Comment posted August 6, 2009 @ 5:13 am
Hell, appraisals are pure fraud anyway. Read: “The Truth About Real Estate Appraisal” by Stephen G. Bishop, and you'll realize appraisers have been inflating property values for 50 years. We're better off without them.
Comment posted August 6, 2009 @ 6:12 am
Why, exactly, should short sales and foreclosures not be included in the comps? As a buyer, to me it's all one market.
Comment posted August 6, 2009 @ 12:16 pm
Are Less Qualified Appraisers are benefited by this new Regulations!!!
Comment posted August 6, 2009 @ 5:15 pm
The Appraisal Institute does not certify appraisers. Only the states can do that. The Appraisal Institute offers “designations” indicating completion of higher education.
“Given that one of the corporations is embroiled in the initial scandal, many in the real estate industry question why the resulting legislation assigns such a major role to these entities.”
There is NO legislation. No laws were written. The HVCC is the result of an agreement between NYAG Cuomo and the GSEs. It can be rescinded at any time.
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Comment posted August 6, 2009 @ 9:19 pm
Why is it that industry insiders had nothing to say about appraisers when the market would go nothing but up for 3-4 years. I'm talking about valuations on a neighborhood going up 10-20 grand a month with no protest whatsoever. Hmm, could it be that realtors, mortgage brokers and banks make a percentage off of the sale amount which means the higher the sale price the bigger the commission? come on, foreclosure and short sales should be considered in an appraisal because those homes were sold for x amount and a new buyer should be well aware of this understanding that he may be buying into a situation where at day one of ownership HIS NEW HOME IS WORTH LESS than what he paid. But of course no one is looking out for the buyer as after the sale closes realtor, mortgage broker, bank, etc. has gotten their commission and new buyer is on the hook for a property that may lose its value continuously for years to come. Also, what's up with the attempt by industry players to keep property values artificially high. We have a whole generation of Americans that want to own homes at a fair price, 2-3 times annual income. Home valuations are still historically high. I think its because the baby boomer generation was caught with its pants down thinking that a house should be part of it's retirement portfolio. Who ever put that into the minds of these people? So we have a whole generation with barely any retirement savings that thought that their homes would rescue them via inflated pricing. Meaning they expected the next generation, gen x and y, to come along a pay 6-7 times annual income in price thereby becoming literal slaves to their mortgages. Homes need to be priced fairly so that millions of young Americans can live the dream that boomers were able to experience during their young adult lives minus the nightmare that boomers created as older people.
Comment posted August 17, 2009 @ 1:02 am
The article and the comments all have some truth, in my humble appraisal, but none have the whole picture or the complete truth. Thinking back on the 15 years I worked as an independent (somewhat) residential appraiser, I now believe the best path to truth is the Watergate admonition “follow the money.”
The savings and loan failures, Keating Five scandal, and house price collapse of the mid-80s was supposedly caused by Federal deregulation of banks earlier in the decade. That allowed lenders to combine their mortgage sales and mortgage loan approval departments. The greed of the bankers allowed them to pay mortgage salesmen a percentage of the loan amount. Like good capitalists, the salesmen did everything they could to maximize their incomes and their employers cheered them on.
They were aided and abetted by (and even conspired with) developers, builders, unions, investors, county and city governments, investors, real estate agents, and home buyers and sellers. They created an artificial bubble that inevitably burst.
Appraisers, including Appraisal Institute and other appraisal association members, played their part. In those days, appraisal reports were done on a typewriter. Computer appraisal programs began to appear in the late 80s, which meant you had to have a current program, a computer, and a place to keep them. Records were kept five years in a file cabinet. The typical fee was $250 to $300 per report. You had to have a car and a camera. Many of us gave a portion of our fees to an appraisal company that got the work for us and handled billing and fee collection. We pretended to be independent contractors so that the company would not have to match the social security contribution. To my best recollection, I probably averaged around $100 income per appraisal. That’s before IRS and FICA. You don’t have to be an appraiser to calculate that you had better do 150 to 200 appraisals a year if you wanted to eat. If you had a family, better make that 300. For those who are statistically challenged, that is 300 appraisals in a 365 day year.
I averaged between 12 and 14 hours to complete an appraisal report.
In spite of all this, almost all the working appraisers I knew were competent, thorough, and honest. Yet some of the headlines associated with the scandals indicated developers who had a brother–in-law for an appraiser, and the family appraiser was a liar. There was talk of appraisals faked to double valuation, which allowed the naïve lenders to make a mistake.
The congressman who had led the effort to deregulate banks in the early 80s tried to apologize by reregulating. Guess who he found to be the principal cause and offender in the scandals. Financial Institutions Reform, Recovery and Enforcement Act of 1989 was the new statute’s name and regulate the appraisers was the game. False appraisals were estimated to have caused 1% of the losses, but they got 50% of the corrective measures. Banks were told to try hard to keep their loan salesmen and approvers separate. Banks were also helped to recover their losses by major programs to take over their worth-less assets and RTC (Resolution Trust Corporation) and REO (real estate owned) were added to the national vocabulary. The house building industry, real estate agencies, municipal tax and development authorities, land owners, and investors were not mentioned. The American Dream was preserved, and the largest and most generous political lobbies in the nation were preserved along with it.
As they put it in Wikipedia “Title XI of FIRREA empowered federal mortgage regulators to adopt standards for real estate appraisal and promulgate licensing requirements to the states. To accomplish this, the Appraisal Subcommittee (ASC) was formed, with representatives from the various Federal mortgage regulatory agencies. The ASC provides oversight and input to the Appraisal Foundation, which in turn promulgates the Uniform Standards of Professional Appraisal Practice and the minimum standards for appraisal licensure.”
Note that was 1989.
Standards of appraisal were not all that standard. If a potential borrower went to a local bank and used a local real estate agent, that borrower might well get an appraisal cooked to taste. City dwellers were not all that safe. A local celebrity newspaper columnist and her husband agreed in their divorce agreement to have the family home appraised for a fair valuation. The three appraisers selected were recognized icons of the profession. Predictably, their independently appraised valuations differed. Shockingly, their valuations were, in round numbers, $500,000, $700,000, and $900,000. Of course, that was thirty years ago. In 2007, it might have been $2,000,000, $3,000,000, and $4,000,000. Next week it might be $1,000,000, $2,000,000, and $3,000,000.
I do not know whether FIRREA or the threat of liability or admonitions of religious leaders have brought reform and total honesty to the lending business since I left it. I suggest that, if you are interested, you should check the income tax returns of your appraiser, your loan officer, your real estate agent, local government officers, and anybody else who stands to profit from your transaction.
Pingback posted August 20, 2009 @ 10:43 pm
[...] Martha C. White wrote an interesting post today onThe Washington Independent » Rules to Regulate Home Appraisals <b>…</b>Here’s a quick excerpt [...]
Comment posted August 25, 2009 @ 3:54 pm
You missed the BIG ONE.. Some states have what is called a “Mortgage Survey” of you land. IT IS NOT real survery, it is a “Process” and you just might now own what you think you own.”Process” looks like a 'Survey” but is NOT A BOUNDARY SURVEY. We moved to TN, our “Closing lawyer AND Mortgage Co approved the “mortgage survey, then demanded we get title ins. WHICH the CLOSING LAWYER sold us. We later put in claim to protect from land grab, told by Ins Co, “You do not have boundry level survey so claim is invalid” Lawyer would do nothing. We found on TN Suivey Board Site “do not use Mortgage Survey as criimal charges might result” TN Dept of Ins said “to bad”. Other states have same, under dirrerent names. so be VERY careful of might find neighbor running road into your front yard as we did and NOTHING stopped them. as well as paid $400 of useless ins sold to us by OUR closign lawyer that APPROVED the survey. So NJ you claim to most corrupted state is in danger.. NO media will touch it as fear to loose RE ads as would outrage public and upset RE industry..
Comment posted September 5, 2009 @ 4:11 pm
Yes, yes, everyone knows a little corruption greases the wheels of just about anything. Look, the whole point is to ALLOW home prices to defalte, it sounds like you might not know this since the only people you talked to for this advocacy piece were people heavily invested in the housing bubble.
Oh gee, what we have now is “artificial depression” of the housing market. Yeah right, let's all take the wolves seriously when they tell us they guard the hen house best. Come on, how about just a tiny sliver of balance here?
Comment posted September 13, 2009 @ 5:38 am
The whole idea of an appraisal became obsolete when banks stopped holding their own loans and just started selling them off. At that point it was about churning volume and checking check boxes. They made their money on fees instead of holding a performing debt.
Of course industry insiders want to go back to the go-go days of easy money- they're aye-holes and don't care what happens to our economy.
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Comment posted June 29, 2010 @ 7:30 am
I disagree. I am seeing that experienced residential appraisers are leaving by the thousands. Our state was never affected by the real estate bubble yet we've lost 3/4 of our appraisers (nearly all were experienced). Why would anyone with any degree of intelligence remain in a business after they were forced to surrender nearly every client they'd spent their career attracting? Why would an appraiser remain in business after being told that would be forced to give away 50% or more of all future income to the person ordering the appraiser. I have a nephew in first grade that's smart enough to see through to the flaw in that business model. Perhaps the newer appraisers just aren't up to speed yet when it comes to figuring out these things. I suspect that many confuse staying busy with turning a profit. They'll learn the difference soon enough though via their wife's frying pan or through bankruptcy court.
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Comment posted July 3, 2010 @ 3:00 am
Of course industry insiders want to go back to the go-go days of easy money- they're aye-holes and don't care what happens to our economy.
Comment posted July 22, 2010 @ 12:58 am
As we've all seen, home prices have dropped to the lowest figure ever and buyers don't have the money to purchase them. The process of selling or buying a house should be facilitated, not tripped by complicated and costly procedures like an appraisal.
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Comment posted August 4, 2010 @ 6:23 am
Appraisal process can be fake, just pay the people who come to do it some cash!
Comment posted August 10, 2010 @ 8:37 pm
I'm a fan of my AMC. I do wish the HVCC mandated competition, that is, that no lender could require an appraisal from any specific AMC. That would level the playing field significantly and get rid of the large majority of non-market problems people are having with appraisals.
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