A Possible Solution to Customary & Reasonable Fees Read more: A Possible Solution to Customary & Reasonable Fees

 

Over the past five years, a major subject of talk in the appraiser world has been that of Customary and Reasonable Fees.  Unfortunately, much of the dialogue has been mostly one-sided.  We tend to do a lot of gripping about the fact that many of us are not being paid what is “customary” or “reasonable,” but there are very few solutions offered up.

When I was young and would sometimes (not often, of course) complain about this or that, my father would always say, “Don’t come to me with a complaint unless you have a possible solution.”  It was sound advice then (though I did not appreciate it at the time), and it is still good advice today.  Though it may not be completely up to us what happens in the world of appraisal regulation and enforcement, it is clear there is a problem.  It is also clear there are very few voices offering up potential solutions.  One of the thought-leaders of our day in the appraisal world is that of Mike Ford.  Mike is a forward-thinking appraiser who aligns with me on many principles of finance.  We both agree that the best, most perfect solution to our current problems is the old “Invisible Hand” of the free market.  However, we are not blind to the fact that we are far enough down the rabbit-hole with over-regulation at this point that it is simply not pragmatic to believe that we can just wave a magical economy wand and expect all of our problems to be solved through the thinking of Adam Smith.  We have to work within the system we currently have (while simultaneously nudging the system itself in the right direction).

Mike recently wrote two blog-posts about the gravity of our C&R situation and (Hallelujah and Praise Be) actually offers up some possible solutions.  These articles can be found (and should be read) here:

http://appraisersblogs.com/appraisal/free-enterprise-an-appraisal-myth/

and here

http://mfford.com/html/c___r_fees.htm

Though Mike will freely admit that the solutions offered are not perfect, they are at least a starting point (and that is a heck-of-a-lot more than most of us are doing).  I sat down with Mr. Ford recently to discuss these two articles, why we find ourselves in this current C&R crisis, and where he sees the profession going from here.  You can listen to my interview with Mike on both iTunes (Apple) and Stitcher Radio (Andriod) or even at your desktop.  Just click the appropriate link below, find Episode 061, and join the conversation.  While you are at it, subscribe the the podcast and listen twice a week while we discuss the ins and outs of the appraisal world.

Tunes:  https://itunes.apple.com/us/podcast/the-appraiser-coach-podcast/id966765322

Stitcher Radio (Android):  http://www.stitcher.com/s?fid=61077&refid=stpr

On the Web: http://theappraisercoach.libsyn.com/

 

Original post can be found on AppraisersBlogs.com HERE

25 Comments on “A Possible Solution to Customary & Reasonable Fees Read more: A Possible Solution to Customary & Reasonable Fees”

  1. Pingback: A Possible Solution to Customary & Reasonable Fees Read more: A Possible Solution to Customary & Reasonable Fees - Appraisal Buzz

  2. There are currently a number of things about to happen in the residential appraisal industry that are going to cause changes to the way appraisers are compensated for their work. Let’s face facts, the residential appraisal has become a commodity available to the lowest bidder. The barrier to entry into the profession has typically been very low and until 20 years ago an appraiser didn’t even need a license. That fact is changing, education and experience requirements are increasing making it more difficult to become a real property appraiser which is slowly eroding the supply of residential appraisers. Further, the addition of AMC’s to the equation has held fees for residential assignments at a level that is not sustainable and unpalatable to most seasoned appraisers. The change in compensation is also causing appraisers to leave the industry further limiting the supply of available appraisers to complete the work load. We already know that the number of licensed appraisers is declining.

    Eventually, when the demand for residential appraisals exceeds the supply of appraisers, clients will seek quicker delivery and will pay higher rates for that service. However, the industry needs to understand that if the pendulum shifts too far in the appraiser’s direction the next shift will be more substantial than the last. The wheels of value models are already turning as Fannie and Freddie continue to collect data in an attempt to demand more reliable and consistent appraisal reports. It is possible that some day the only service the residential appraiser will only be needed for is to confirm the property exists and possibly measure it and determine its condition. I had a computer modeler for Wal Mart once tell me “we can model anything”. I am sure that is true.

    Now the government is getting into the business of regulating fees. Some appraisers think that they will eventually receive higher fees because what they are currently being paid is not customary or reasonable. Some probably will. However, you might want to ask your family doctor if they think the fees paid by Medicare are reasonable or customary. I bet they say no. No good can come from government involvement in the regulation of fees and, as an industry we should reject their efforts. The fact is that appraisers are paid based on their skill level that includes not only their ability to appraise real property but also their ability to market and operate their business. The first step appraiser’s need to take is to stop accepting low paying assignments from AMC’s. Market your services for title disputes, estate valuation, divorces and other users and get out of the AMC welfare system. Our firm refuses to work for AMC’s; if the word Management comes up on the caller id, we don’t even answer the phone. Guess what, we are busier than ever and well respected in our market.

    1. Jerry:

      The new requirements that make it “harder” to become an appraiser is a good thing. Before individuals were required to have a college degree to become certified, a high-school dropout could complete an appraisal. The only part of the college degree requirement I don’t like is that it doesn’t require a required number of hours in subjects that are pertinent to what we do (i.e. economics, statistics, English, etc.). There was a time when a person could waive the college degree requirement if they had a specific number of hours (21 I think) in those subjects and 1 or 2 others. If those subjects meant so much that the degree requirement could be waived then why not require them for those who do have a degree? For instance, would you want someone doing your income taxes that didn’t have education in accounting? Or an attorney hearing your case who didn’t have one course in law? Of course not. So, why should an appraiser be awarded a certification when they have no credit hours in economics, statistics, English, or other courses that are important to our field? They shouldn’t.

      Second, as a designated member of the Appraisal Institute, I’m troubled by their lowering of the “standards bar” to earn a designation. The AI used to have a bar that was higher than a state regulatory agency, but recently with the new model they’ve implemented, they’ve allowed the state regulatory agencies to give a “thumbs up” on the majority of the experience required to obtain a designation while experience screeners only have to pass a minority of that experience. That is troubling to say the least. What’s happened? I’ve seen a number of individuals obtain a designation who do not deserve it. I’ve reviewed their reports and I can tell you that I am baffled by the fact that someone signed off on their experience if that is the typical work that the individual does on a daily basis.

      As it relates to AMCs paying lower fees, I can tell you that our firm does work for AMCs and if it is an area that we are willing to cover, but no one else will, then we pretty much name our fee and get the assignment. The problem isn’t the AMCs proposing low fees. The appraiser does not have to accept that fee. That blame falls on the appraiser for accepting such terms. There is no law that requires an appraiser to accept a fee if they don’t wish to do so. Our government isn’t that overbearing, although some like to portray it as such.

      Speaking of appraisers and fees. Customary and reasonable is a friendly piece of legislation to the residential appraiser. While it does have government fingerprints on it, it does not allow the government to dictate what an appraiser charges in terms of a fee. It only sets the MINIMUM that can be paid. That’s a good thing!! If the C&R fee in your area is $400 then there is no more of the AMCs throwing out a fee of $300 and expecting you to accept it. You simply tell them that the C&R fee for the area is $400, so $300 is not acceptable. Now, if you or any other appraiser accepts $400 then that is up to you. The government nor anyone else is going to say that you can’t do that or that you have to accept it. Instead, you could say, “The customary and reasonable fee for this area is $400, but given the travel time, the size of the residence, and the lack of an MLS, the fee will be $600.” There is no law that says you can’t do that. In fact, if you and others did just that then the fees would increase. Of course, it is up to the AMC to accept your terms, but odds are there is someone out there who would do it for the minimum amount. Which brings me to my next point.

      Why do residential appraisers get paid a lower fee? I think they are doing it to themselves. I’ve reviewed a number of residential appraisals and I can tell you that 99% of them are not compliant with USPAP, and about 90% of those should be submitted to the state regulatory agency for their review. There is no summary of how they derived their adjustments, there is no summary of highest and best use, there is no expansion of the scope of work used to complete the assignment beyond the boilerplate contained on page 4 of the form – a scope of work that says what the appraiser “should do”, but not what they “actually did”. Having said that, could it be that low fees are based upon the typical residential appraiser not having enough confidence in their product to justify a higher fee? I can tell you that our residential appraisers justify every single adjustment in the report. Yes, EVERY SINGLE ADJUSTMENT. We do not allow reports to leave this office without every adjustment being justified with a summary of how it was derived – for both residential and non-residential assignments. Before anyone chimes in with “there’s no way you can do that”, I can tell you that there is a way. All you have to do is analyze the sales, talk to people familiar with the transactions, etc, and take classes with a reputable education provider like the AI. So, yes, it can be done. We get decent fees from AMCs and even from our non-AMC-affiliated clients because they have confidence in our work. I can tell you that it isn’t enough because of the others in the area who are charging lower fees for work that is less reliable. Why? Probably because they don’t have enough confidence in their product to justify the higher fee. Heck, I can tell you that even at $300 that the client overpaid for the service based upon the majority of those appraisals that I’ve seen.

      That is the real problem facing the residential appraisers today. There are too many people doing this that have no idea what they are doing and are holding down fees for those of us that do. Until those individuals change their business model, obtain competence, retire, or a state regulatory agency pops them with a harsh penalty, then the industry will continue to suffer. Not just for residential appraisers, but for non-residential appraisers as well.

      So, let’s not blame the government or AMCs. Those are the easy excuses to put on the table. The true problem lies with those in the industry who have no business doing appraisals and are charging lower fees as a result of it. If you know what you are doing, produce a quality product on which your clients can rely, and feel as though you aren’t getting paid enough for it then look no further than your competition that is the complete opposite of your product and charging a lower fee.

      1. A LOT of outstanding points KY. I disagree re college requirement for a residential appraiser. Your own anecdotes tend to support me on that. Even designation no longer means what it used to mean. We have BOTH seen far too many MAI prepared reports that fail in the same areas that you cite for generic residential reports. N1 makes a nice looking report, but it still allows a lot of pertinent data to be omitted with no one the wiser except another trained professional. Respectfully AFR appraisal is NOT rocket science or brain surgery. Does a relevant degree hurt? Of course not.

        Real estate participants include both degreed and non degreed buyers. Some purchases are based on sound economic analyses. Others are purely subjective or emotional. ANY good agent (with or without degree) can tell us what a property should sell for in their market area. You and I may arrive at the result through the artful application of scientifically based principles; and they may still have the ‘right’ answer despite our “supported” adjustments. (OK, usually we are going to be right, but the point is still valid). NOTHING about single family residential appraisal requires a degree. Nothing. I’ll concede degree or equivalent for C&I or new subdivision work.

        I applaud your supporting all adjustments ( and suggestions to others on how to do the same). Regrettably many / most appraisers don’t even know what that means anymore.
        We both see that finding reinforced every time we hear how someone is producing UAD/URAR appraisals AND reports in under four hours. Heck, my driving time is usually three hours!

        KY, it sounds like you still try to produce a professional product for every appraisal report that leaves your office. I suspect you have not bought into your AI President’s belief that appraisals are nothing more than commodities to be run off a database driven assembly line.

      2. LOL. Support every adjustment do you? I wonder do you also reconcile and report the quantity and quality of the data incorporated to derive those adjustments? Do you inform the client that the method is generally unreliable due to the lack of available data and multiple infused opinions? How about the fact that buyers simply don’t purchase property like that? Do you reconcile and report the method as a whole as it affects the results of your report in addition to reconciling and reporting each and every individual adjustment? I have a serious problem with appraisers who run their mouth shouting how they “support” each and every adjustment and “you should too” or “and that makes us awesome”, with no discussion of the serious flaws in the method. Guess what, I support each and every adjustment with market data too, but that doesn’t mean its worth the paper its printed on. I like much of what you have written in your post, however I think Mike Ford does a much better job of keeping it real.

    2. Jerry, I think you are on point, and I agree with everything that you are saying. In fact I have already had that like of thinking before I read your comment. I think that the AMC’s will die a natural death, at least the bad ones, and its not just their low fees, and extremely slow pay turn times, their endless revisions from someone in their firm that does not have a clue, and is just going down a check list, and has not read the report to begin with, and a detailed check list that is designed to cover every type of financing, prevent profit being made from their orders that are usually difficult assignment to begin with because every other lender/appraiser has already turned down the assignment and it is a last ditch effort for financing.
      I do the same thing with the phone calls and emails from AMC’s,,,ignore them. And like you, I am slammed with work from clients that respect me and know that I will work late into the night if I have to to keep them on schedule.
      When the rest of the appraisers wise up and realize that they are making little if any profit off of AMC’s and quit accepting orders from them, and pick and choose their clients who pay reasonable fees, have good pay turn times, and have legitimate revisions, then things will improve for them, as well as the profession as a whole.

      1. Victor, respectfully I disagree. AMCs have been around since before 1990. LSI and ATM come to mind. The reason I do not think your scenario will ever come about is due to the competing interests at play. The AI WANTS to commoditize appraisals. They WANT to rely on “mega data” based AVMs and have the standards changed to permit newer, cheaper, non USPAP compliant products. Oddly enough though, even under their optimal scenarios we do not lose the AMCS. They are here to stay. They give banks LOWER OVERHEAD COST appraisals. No staff required. FNMA WANTS AVMs or some similar spurious product based on THEIR mega data base…which we all know to be flawed from the outset, based on their own admissions!

        The GREAT goal of all AMCs, software designers and bureaucrats is to eliminate the individual appraiser and replace us with a “close enough” automated alternative. IF that were possible, then ZAIO would not have collapsed. IF that were possible then Zillow would already be used. The FACT is that NOTHING replaces an onsite inspection by a professional that knows local market nuances. Imho.

    3. Jerry, While ONE peer group in the appraisal profession is advocating treating appraisals as a commodity, even it’s own members are not fully convinced that is the right path. But your point is made. Lenders are treating appraisals as commodities, and perhaps they need to be reeducated, rather than to be capitulated to.

      Government regulations have ALWAYS affected your and my work. In 2009 it got into an area that started affecting what we could realistically charge if we wanted to continue our habit of eating regularly. It destroyed established free market based relationships that had existed for decades, virtually overnight. So the push back now is not a ‘new’ government regulatory burden, but rather a correction of one that should never have happened in the first place.

      Not everyone has the luxury of boycotting AMC work. Heck, even I do one (UAD) every two or three months just to make sure I remember how. In some markets, low AMC fees have already had a spillover effect into non AMC work for both residential AND commercial fees.

  3. The issue I see in the tables provided by Mike, is that I would have to take a pay cut? I am wondering if those numbers are without payroll loading? I am hesitant to use government tables due to the vagaries of time/change.

    1. Excellent question Mark! I don’t see ANYONE taking ANY kind of cut unless (possibly) you are already grossing over $100,000 as a sole proprietor, single person appraisal office. Double check the charts Mark. Read the one at the very end-that’s the summary. These are suggested default MINIMUM C&R fees where no other C&R fee tests exist (California for instance). IF an AMC were to allow AL’s with 3 years or less, the MINIMUM fee for a non complex FNMA SFR would be $515; but since MOST appraisers have over 15 years experience anyway-my suggestion is $585. IF on top of that, they ALSO require residential certification (as several due to even be allowed on their panel) then the fee would be $685. They have to PAY for the enhanced skillset and experience the AR provides. FHA would be higher.

      So, unless you are routinely collecting per assignment fees for non complex work of $585 or more; no you will NOT work for less. Most are only getting $300 to $400 for these now.

  4. I am always suspect of any post that does not offer up the obvious solution and pussy foots around with appraiser sympathetic complaints and ineffective solutions. CHANGE THE BUSINESS MODEL OF THE AMC by government regulation. The business model of the AMC is based upon one simple strategy; maximize profit by reducing appraisal fees. Anything else you hear is just lip service. What, of the host of problems that currently face our profession, would not be entirely fixed or at least vastly rebalanced if appraisers were no longer exposed to the unrelenting pure price competition they are subjected to by the AMC. Of course, it is sensible regulation to separate lenders and appraisers but then to allow the financial industry to write thel C & R regulation shifting the administration costs of procuring the appraisal from the lender to the appraiser? Are the consequences of this really that surprising? The AMC should continue to provide appraiser options to the Lender but THE AMC SHOULD NOT BE ALLOWED TO COLLECT THEIR FEE FROM THE APPRAISAL FEE. It is the banks cost of doing business, not the appraisers. Duh!! How many less employees would AMC need if they did not need a army of telemarketers constantly haranguing appraisers about their fees so they might suck a couple more dollars from the appraiser. Is that cost effective to anyone but the AMC? Do you think big financial institutions do not know exactly how to wield they huge lobbying power to align the system for their benefit? At worst they know they are relived from the administrative costs of paying the AMC and at best they can degrade the appraiser profession to such a degree their value is no more than that of a AVM. Why this “solution” has not been enacted is a testament to the corruption of financial system, not that it has not been offered up.

    1. S. Levers: You are right! Right idea, wrong “enemy”. It is not the AMCs that are setting fees anymore. It is the banks that hire the AMCs that set the fees. Especially under TRID. Even when an AMC agrees with you that a higher fee should be applicable (lets say $1,250 to $1,500), they cannot get the banks to accept it and authorize higher fee levels. he bank expects THEM to eat the cost difference. So, they originally quoted the bank $500 to $550 (TRID rates); then they set aside the $25 to $75 kickback that they are paying the banks executives or appraisal ordering staff on a per assignment basis in order to use their AMC in the first place. Lets say they only charge $75 to $100 for their AMC fee. At the LOW end of the ranges I cited, there is only $400 left for the appraiser. Even if the AMC forfeits their fee (and many do), they cannot et remotely close to the fee you need. In VERY RARE cases they may get $750 out of the bank (borrower actually), but that is still far short of the $1,250-$1,500 “reasonable” fee required.

      Price competition from bank to AMC is less prevalent than you believe since the fees are essentially already fixed by the banks themselves. (Try proving THAT one, though we know the amount under TRID is now $500 to $550). The appraisal “fee” is set when the loan officer makes the initial disclosure to the borrower when they complete their application. The reasons ‘why’ that fee is not likely to ever change are many and the topic of its own article.

      The fact that TRID still allows the bank fees; work solicitation kickbacks, and AMC service fees to be concealed as “appraiser fees” proves THEIR lobby is stronger than OUR lobby. So far. CFPB needs to make some significant changes to TRID. The American Guild of Appraisers wrote to them, along with the FFIEC yesterday adding our voice to those of several others with TRID concerns (including several perceived ‘competing interest’ groups).

      But, what it is REALLY going to take is YOU people adding YOUR individual voices to one that has ‘access’ to legislators and regulators. My suggestion is AGA, OPEIU but ASA is also a good alternative.

  5. I find that quite a few residential appraisers are simply whiners and complainers especially a large number of “Appraiser Forum” regulars who by the way have over 15,000 posts each telling me how efficient their appraial work is. This “reasonable and customary” nonsense is a government term that means nothing in reality and cannot AND will never be enforced.

    The MARKET should always set the price and if your competitor gets a job by charging $25 less than you, too bad. It’s called COMPETITION and if 95% of residential appraisals are not so complex that nearly every certified appraiser is qualifed to perform. And don’t start about “quality” of work either because there are plenty of really good appraisers I know that are so efficient they can charge so-called “below market” fess and still make good money.

    So all you folks please keep spending an hour or two on some silly crybaby appraisal forum complaining about the job I just got that you overbid. Tough luck….

    1. You might benefit from READING Dodd-Frank. Level playing field competition/free enterprise IS healthy. When it is derived from legislative cronyism it ceases to be so. “Whining”? I spent 30 years building a credible business reputation and diversified client base. HVCC threw that all out the window overnight. Now, tell me ONE market in America where “the market” is setting TRID fees. Just one. FACT is that most lenders and banks present a fee of $550 to be paid to the AMC and the usual $35 to $75 kickback comes out of that; along with the $100 to $200+ AMC fee BEFORE the appraiser is given the leftovers.

      Now an observation I’ve made over the years is that there are a number of people that are either generally contrarian, OR perhaps have conflicting interests (such as a part ownership in an AMC) and seek to obstruct any form of problem resolution or progress among and for our profession. Just an opinion, of course.

      1. Here’s a little advice about dealing with the big, bad, and (allegedly) corrupt AMCs, Mikey……

        DON’T.

        I perform an average of 300 residential appraisals per year and less than 5% are for the AMCs. And those are the reports that no one else wants and I can name my fee.

  6. If you listen to Jerry, all appraisers are “bad” or 90%. Wow, Jerry Ignorance is bliss!., Low fees are a result of an over supply of appraisers. Simple economics. We have appraisers like the “appraisers coach” that are willing to accept any job, no matter
    how low the fee (how many jobs has the appraiser coach accepted that were below $250.00). The appraiser coach is part of the problem, not the solution. If I was a lawyer, the appraiser coach would be “X appraiser coach”. How does he make $200K per year. The appraiser coach takes all jobs, fees low or not! He has hired low paying “assistants” to due his appraisal work. His assistants complete probably 90% of the work on the appraisal. He needs volume to stay in business..

    1. 1. Supply and demand determine price. Standard economics.
      2. An appraiser with a degree in Marine Biology may not be a better appraiser than the one without a degree but more professional appraisal experience.
      3. Senior appraisers are jumping ship faster in the past three years than ever before due to all the “regulations”.
      4. Banks own most of the AMC’s. I doubt they will regulate themselves.
      5. Banks contribute big campaign dollars to political campaigns. I believe 13 top bankers are now Obama cabinet members
      6. The top 5 banks have paid over 50 BILLION dollars in fines and settlements – I hardly doubt things will change. That’s BILLION. .
      7. Appraisers are not allowed to do the appropriate job in the “everyday” appraisal market. Quantity is superior to quality. Always has been in my 25 years experience. I choose not to work for those companies, but some do not have that choice.
      8. Some lenders do not even know nor understand USPAP or FHA guidelines
      9. Mortgage processors should not be paid commission
      10. Realtors should be held to a higher degree of professionalism.
      11. Reported statistics on Realcomp and local MLS are incorrect and skewed: DOM especially do not represent a true marketing time. Therefore, to complete an accurate 1004MC is impossible.
      12. Appraisers in Michigan inspect a property and have numerous other “employees” type up the report. That may include shooting comparable photos. Any appraiser who can complete more than 12 reports a week is not completing his/her own work. Period.
      13. Fannie Mae CU makes no sense. Get out of my report. Fannie is only analyzing comparables 1-3. Comparable 4 could justify Fannie Mae letters being received, but are not considered.
      14. Geographic competency should matter

      Could go on and on, but that’s good for now. Best wishes to all!

  7. “Kim says:
    October 29, 2015 at 1:23 am
    1. Supply and demand determine price. Standard economics.”

    Brilliant!

    Good ol’ Mike must have skipped Economics 101 with all his “GSA PRICING” model.

    What a load of nonsensical BS.

  8. So I am going to chime in here. First of all I love what Mike has written in the two links provided by the coach – thanks. I find them both to be about the most eloquently written descriptions of our plight yet. And yes, I used the word plight. This industry is heavily regulated and because of that, the “free market” principles that govern most other industries do not always apply. I get a little tired of appraisers who just say we should just suck it up and accept it. I can guarantee that is exactly what the lobbyists on the other side were hoping for and counting on. But enough of that.

    I love the discussion of how we should probably get paid more for what we produce. I agree. We make too little based on our skill level and time, as compared to comparable professions. I think an appraiser in an average market (meaning the cost of living is average, so NOT in New York city for example and maybe a guy in St Louis) should make somewhere between $50,000 to $80,000 a year as an employee or sole proprietor for a standard 40 hour work week. I think our skill level ought to dictate that amount. Now if you are slow and you make less, too bad. If you are fast and make more, good for you. I am talking average here. We’re appraisers, we should all understand an average.

    But what I really wanted to talk about is the other side of the story, our clients. There is this mentality among appraisers that if the client asks for more work, we ought to in-turn receive more money. Well, I suppose we should. The part of the equation that gets left out at that point is, there is only so much money a consumer is going to be willing to “gamble” on an appraisal when they apply for a mortgage loan. THAT AMOUNT IS WHAT DICTATES THE AMOUNT WERE ARE GOING TO GET PAID!!! Now, I am a guy who hates when people type in caps, but I felt it was justified and I would love if everyone read that sentence over and over and over again. Let it sink in. Accept the reality of it. Until the day lenders will pony up for appraisal fees themselves (ha ha), our fees will be dictated by the consumer gamble threshold (lol can I call that the CGT).

    My solution is to advocate for work product that takes less time to produce, not higher fees for more work. That’s how we will get a raise and keep the mortgage cash flowing. I can produce a USPAP compliant report, every bit as credible as the 30 page monsters, (and do on a regular basis for consumer clients) for nearly half of what we charge now. I think that’s the answer. Appraisal is not rocket science and the more people treat it like it is, the less reliable the reports are, IMHO. We get paid to be unbiased, not because appraising property is all that complicated.

  9. The Banks will replace the residential appraisal report with AVM’s within 5 to 10 years. Congress will approve, at the urging of the Banks,
    who supply the politicians with campaign contributions.

    1. No AVM can calculate physical condition, quality and good taste – these are all opinions that have a significant effect on value.

  10. I don’t think appraisers need a complete college education for this field. Mostly they need a ‘real’ involvement such as an interment period.

  11. Some AVM’s send out multiple request for fees below the customary and reasonable. Since it is prudent for appraisers to research the property prior to accepting the appraisal, this requires time to be expended. If appraisers charged for providing fee proposals that are not accepted there would be less “bidding” for services. These charges could be credited to the fee if it is accepted. The requirements of quick responses are not professional. This is not a horse race. Many do not extend the courtesy of responding that the appraisal fee was not accepted. Perhaps one might consider a time limit for proposal acceptance.

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