An AMC’s thoughts on the repeal of Dodd-Frank……I recently read an article titled “An Appraiser’s Thoughts on the Repeal of Dodd-Frank” by Tom Horn, and I found it interesting that our thoughts lined up so well on some key points about what we would like to see remain and what we would like to see removed if Dodd-Frank is changed.
Several key points that we are definitely in agreement on is the independent ordering of appraisals and appraisal independence. (Tom caught some flack over his opinion……but I agree). This is such a key point in preventing any value pressure…..it protects the lender and the appraiser from undue influence. After discussions with several Compliance Officers, this process has been a great tool for true appraiser independence. (This is a hotly debated topic by many appraisers….the comments in the article were interesting.)
Total disclosure of the appraisal fee and the appraisal management fee should have always been a key factor. SAMCO has always disclosed each fee in our invoice to lenders. They never have to wonder what the appraiser is truly being paid, because it is there in writing. I never realized that was a problem until last year and I was reading the blogs. Our platform is set up for full disclosure, and that has been a great tool for lenders. If we have a problem order…they know about it too.
AMC’s (at least SAMCO does) currently help with limited communication with the appraiser after the appraisal is completed. Currently, there is no regulation that stops the borrower from contacting the appraiser directly when a value has not met expectations. We intervene on behalf of the lender and the appraiser by offering a reconsideration of value process with set procedures.
This AMC looks forward to changes for the appraiser /trainee inspection requirements. We have worked with several talented trainees in the past, and we think this will benefit the appraisal profession.
No one knows what the future may bring in regulatory changes…..but I think that appraisers, lenders and AMC’s can form a great team. I will end with a conversation that I had yesterday with an appraiser, they had worked 20 years with a lender, already been through one AMC change with them, and SAMCO was the second. They said as an AMC …you guys are different. They liked working with us, and we really like to hear that. WE WANT TO BE DIFFERENT. We appreciate the feedback, the good and bad ….we are always striving to make improvements.
Everyone has their opinion of AMC's, and these are just my thoughts on the subject.