 |
>> See Past News Editions >> Click to Print Protect your license and your livelihood with the Expert’s Guide by Tim Andersen, MAI. Click now2015 AMC Guide Increase orders, turn down low-fee AMC work. Click now |
Facing License Denial, Coester Sues Virginia Board
by Isaac Peck, Editor
Facing denial of its license to operate an appraisal management company (AMC) in the state of Virginia, the AMC Coester VMS has filed a lawsuit against the Virginia Real Estate Appraiser Board alleging that the Board is engaged in “a conspiracy to restrain and monopolize trade” and is operating in violation of federal antitrust laws.
The suit follows Virginia’s recently passed AMC licensing laws, which set an August 18 deadline for applicants to obtain AMC licensure or cease operations in the state. The Board has issued dozens of AMC licenses but selected Coester for closer examination. On July 15, Coester attended an informal fact-finding conference and addressed several of the Board’s concerns, including Coester’s history of consent orders and settlement agreements in five other states, for alleged violations of state laws: Maryland, North Carolina, Tennessee, Louisiana, and Minnesota. The allegations against Coester in these states include: unlicensed AMC activity, false advertising, failure to pay appraisers on time, failure to pay customary and reasonable fees, failure to respond to requests within the time period specified, failure to submit biannual certification, as well as USPAP violations committed by Brian Coester himself. (Click here to read the consent orders and settlement agreements in their entirety.)
Coester defended its actions by saying it has taken “remedial efforts” to address the issues raised in the consent orders and that it has recently implemented a new compliance management system that is designed by “expert business consultants,” many of whom are CPAs.
However, on July 28 the reviewing officer of the informal fact finding conference issued a recommendation to deny Coester’s AMC license in Virginia, citing “serious oversights in the planned compliance management system.”
Background
There seems to be little doubt that the Board is within its rights to refuse licensing to Coester. According to Virginia’s AMC Regulations, effective in February 1, 2015, the Virginia Appraiser Board is empowered to use its judgement to decide whether to issue a license to an AMC that has been subject to any form of adverse disciplinary action:
“The board, in its discretion, may deny licensure to any applicant who has been subject to, or whose controlling person or responsible person has been subject to, or any person who owns 10% or more of the firm has been subject to, any form of adverse disciplinary action, including but not limited to (i) reprimand; revocation, suspension, or denial of license; imposition of a monetary penalty; requirement to complete remedial education, or any other corrective action in any jurisdiction or by any board or administrative body or (ii) surrender of a license, a certificate, or registration in connection with any disciplinary action in any jurisdiction prior to obtaining licensure in Virginia.”
(story continues below)
(story continues)
Rather than arguing the Board’s power to deny it a license, the core of Coester’s suit alleges that the Board is engaged in anti-competitive behavior- by trying to restrict Coester from conducting business in the state. Coester alleges that the denial of its license constitutes an “unreasonable restraint of trade because it prevents a large AMC entity from entering the marketplace.”
Coester states that Virginia accounted for 10 percent of its national business and that it has completed 10,113 appraisal assignments in the state since 2013, making Virginia its second largest state by volume. If denied a license, Coester says it will “permanently lose its customer base in Virginia if the Board’s anticompetitive and pre-textual denial of CVMS’s license occurs on August 18, 2015.”
The suit calls the licensing process a “sham” and makes repeated references to the Board’s “bias,” accusing it of “conspiring” and “plotting” to harm Coester.
Coester claims that the very structure of the Board is anticompetitive because, by statute, six of the 10 Board Members are required to be fee appraisers. The statute allows for one AMC representative to sit on the Board, but Coester alleges the individual serving as the AMC representative is actually an appraiser, not an AMC, and, consequently, seven of the 10 Board Members are fee appraisers. Coester alleges that this gives fee appraisers a “super-majority” on the Board and refers to them as “direct competitors” who ensure that all decisions made by the Board are in the interests of fee appraisers.
Coester further claims that several of the Board Members are also officers in the Virginia Coalition of Appraiser Professionals (VCAP), a trade association of independent fee appraisers that Coester says has “conducted an active campaign against AMCs” and whose members have repeatedly complained about the low fees paid by AMCs. The suit cites many internal emails between Board Members to support its claim that the Board is biased against Coester.
While each of the Board’s ten individual members is named in the suit, it is unlikely that they can be held liable as individuals for the particular actions of the Board.
AMCs Save Consumers Money- What?
In the suit, Coester makes an argument that will certainly raise some eyebrows among appraisers. Coester says that because AMCs pay appraisers less than non-AMCs, the removal of Coester from the marketplace will harm the public. Coester states that it is a “lower cost competitor” of the Virginia Appraiser Board members, and other appraisers throughout the state, asserting that the denial of Coester’s application will “drive up the price of single family residential appraisals” and will increase costs that “will be passed on to homebuyers.”
(story continues below)
(story continues)
Coester cites a 2014 Customary and Reasonable Fee report by Virginia Tech which states that the average fee for an appraisal ordered directly through a non-AMC client is $401, while the average fee for an appraisal ordered through an AMC is $328. Coester uses the Virginia Tech study to suggest that it helps keep fees low for the borrower because the appraiser is paid less when working through an AMC. Coester says if it is banned from doing business in the state, the result will be “raising the transaction costs of residential sales for purchasers and borrowers,” and will “substantially effect interstate commerce.”
Most appraisers understand the disingenuous nature of this argument because the lower fees paid to AMC appraisers, cited in the study, are not the fees actually paid by borrowers. As most appraisers know, AMCs frequently take 30-50% of the “appraisal fee,” so the amount paid to an AMC appraiser is actually much less than what the borrower often pays. Most appraisers will tell you that the fees borrowers pay have actually gone up since AMCs have been shoehorned into the process. As the Network of State Appraiser Organizations (NSAO) put it in its letter to the Consumer Financial Protection Bureau (CFPB): “a consumer might see an appraisal fee for $600 or more with no awareness that the appraiser they met at their home, and who completed their report, is only being paid $300 or less” by the AMC.
Coester also cites the Virginia Tech report as evidence that, by excluding Coester, the Virginia Appraiser Board members are enriching themselves and other Virginia appraisers because the fees actually paid to appraisers in the state may go up because non-AMC clients appear to pay more than AMCs.
Coester Extension
Wthin days of the suit being filed on August 3, 2015, a consent motion was signed between Coester’s attorney and a Virginia Assistant Attorney General (AG). The consent motion specifies that the Counsel and staff to the Board will recommend that the Board defer ruling on CVMS’s application, and that the Board extend the August 18 AMC application deadline to December 2015. This would allow Coester to continue to doing business in Virginia until then. However, the Board has final decision making authority and is not required to follow the Assistant AG’s recommendation. A special meeting of the Board has been called for August 12 to consider and vote on the recommended actions of the Attorney General’s office.
Who is Behind the Lawsuit
The law firm representing Coester in this case is Weiner, Brodsky, Sidman, Kider PC (Brodsky firm). This is the same law firm used by the veteran AMC advocacy group the Real Estate Valuation Advocacy Alliance (REVAA), in past legal filings throughout several states, and the one also picked to represent a new AMC coalition, the National Home Valuation Alliance (NHVA). NHVA appears to be led by former REVAA Executive Director Don Kelly.
In a possible sign of things to come, the very first goal and agenda item NHVA lists on its website is, “to leverage collective resources to affect helpful (rather than harmful) change through multiple targeted initiatives, including litigation.”
Information on NHVA’s website echoes certain of Coester’s arguments, including the concern that state appraisal boards are violating antitrust laws. NHVA’s stated goal is to “vigorously represent the interests of its Members in the home valuation arena before the federal government and state agencies.”
In the PowerPoint presentation from NHVA’s Initial Meeting, found on the group’s website, one slide lists “Key Issues/Opportunities” for the organization, which include:
1. State Appraiser Fee Survey Policies and Requirements
2. Customary and Reasonable Appraiser Fee Requirements
3. Timely Payment of Appraiser Fee Requirements
4. State Appraisal Board Antitrust Concerns
5. AMC Representation on State Boards
6. Required AMC Minimum Quality Control Requirements
7. Appraisal Subcommittee AMC Fee Structures
Note that four of the seven items seem to relate to fees, suggesting that the NHVA is deeply concerned about appraiser fees. It looks like appraisers will have a fight on their hands going forward.
NHVA is representing itself as the advocacy organization for smaller to mid-size AMCs. REVAA charges $75,000 annually for membership and representation. NHVA dues are a more modest $995 a month. NHVA’s stated goal is 30 charter members and says that it sees the over 350 AMCs operating nationwide as potential prospects.
Bigger Picture
Coester’s suit against the Virginia Appraiser Board raises interesting questions for the appraisal industry and for the future of AMC regulation as a whole. In an article published in Mortgage Banking magazine (State of the Appraisal Industry, Volume 27, Number 9), Brian Coester, Chief Executive Officer of Coester VMS, sees a future where appraiser boards will no longer regulate AMCs. Coester argues that “competitors cannot regulate competitors” and makes a bold prediction that this “leaves the appraisal boards…to be completely disassembled and have even less control of the process.” Federal regulators, however, seem to believe that the public is well served by having AMCs regulated by the state’s appraisal board. In fact, the recent “Final Rule” on the Minimum Requirements for AMCs seems to settle the issue.
While the Dodd-Frank Act tasked state appraisal boards with passing AMC regulations, the Final Rule removes any doubt that state appraisal boards have the authority to directly enforce the law and discipline AMCs for violations of the law. Specifically, the Final Rule requires that states have a program in place “within the State appraiser certifying and licensing agency that has the authority to… conduct investigations of AMCs…and discipline, suspend, terminate, and refuse to renew the registration of an AMC that violates applicable appraisal-related laws, regulations, or orders.”
While Coester’s suit may usher in a new wave of AMC-led litigation against appraiser boards, the clear language of the AMC Final Rule leaves little question that the Fed’s intention is for appraiser boards to regulate AMCs.
Working RE is following this story closely and will issue a timely report on the outcome of the special meeting.
Webinar Tomorrow – Help Your Business!
Efficiencies & Increasing Your Business Bottom Line
Presented By: Dustin Harris, The Appraiser Coach
Part 1: August 11th, 10:00 – 11:30 a.m. PST
Part 2: August 18th, 10:00 – 11:30 a.m. PST
“The seminar was very helpful and encouraging in time-saving mobile applications! Thank you for making it available!” – James W.
Are you still hung up on old ways of doing business? Have you adopted the latest technology to help you be more efficient and get more done? Today’s appraisal industry is rapidly changing. With increasing demand on appraisers’ time and attention, it’s more important than ever for appraisers to have the tools, systems, and knowledge they need to leverage technology and run an effective, efficient appraisal office. Whether you’re new to appraising with mobile tools, or you’re looking to sharpen your skills, this webinar gives you actionable steps that you can take today to be more efficient and effective with mobile tools and run your business like a pro. Sign Up Now!
On-Demand Webinars
Did you miss the much acclaimed How to Support and Prove Your Adjustments webinar by Richard Hagar, SRA? Expand your knowledge and learn quick and simple methods for proving adjustments that improve the quality of your reports and help you avoid problems, blacklisting and legal actions. Sign Up Now!
Season Ticket!
Enjoy the entire summer webinar series at your leisure (live and recorded) and save: June, July, and August Webinars (six webinars) for a single price!
Regular Price: $237 Summer Season Ticket: $149
Summer Series:
June and July (available on demand)
–How to Support and Prove Your Adjustments (two parts)
–How to Get What You’re Worth (Working with AMCs)
–How to Work Profitably With AMCs
Enjoy the Entire Series! Save $88 with a Season Ticket!
About the Author
Isaac Peck is the Editor of Working RE Magazine and Director of Marketing at OREP.org, a leading provider of E&O Insurance for appraisers, inspectors, and other real estate professionals in 49 states. He received his Bachelors in Business Management at San Diego State University. He can be contacted at Isaac@orep.org or (888) 347-5273.
>Click to Print
>New: Collateral Underwriter Blog: Find answers, offer solutions.
>Opt-In to Working RE Newsletters
Send your story submission/idea to the Editor: dbrauner@orep.org
by Mike Ford CA AG; SCREA, AGA, GAA, RAA
Consumers do not benefit when fees are unreasonably low. Appraisal report quality suffers. For a buyer it may mean they need to come up with more money (or the flip side, they may have overpaid) from a “down and dirty” quick, cheap “appraisal.”
Taxpayers suffer when every fifteen to twenty years we have some kind of bailout like the S&L bailout (Resolution Trust); or TARP I; TARP II, and QE 1, 2 & 3. Artificially low interest rates are nice for home buyers and refinances but not very good for IRA accounts and other retirement savings funds. American consumers benefit MOST by accurate, honest, competent & professional service.
-by Michael Ford, CA AG, SCREA, AGA, GAA, RAA
In the past few days I’ve had occasion to read MANY blog posts found in both WorkingRE and in TheAppraisersBlog. One post I made even got me an email “clarification” as to the relationship between REVAA ( a 501(c)(6) ) and Coester (none is what I was told ), and NHVA (the attorneys operated ‘alliance’) purportedly supporting Coester; one of whom reportedly is a former executive of REVAA. Numerous emails have gone back and forth between us. I take REVAA at their word that they have no direct involvement in the lawsuits. They HAVE had a past relationship with NHVA’s founders though. Whether its relevant or not, I simply don’t know. It also provided an opportunity to provide REVAA with a summary of ALL the things that I think are wrong with the AMC model as currently operated. My personal impression is that it was politely read, politely acknowledged, and then promptly disregarded. We’ll see as time goes on. But at least REVAA is FULLY aware that they are not dealing with one unknown “nobody” appraiser out in California; but rather the AGA & OPEIU / AFL-CIO if it comes down to a future disagreement. We’ve mutually agreed that communication is a good idea. So, for what its worth, there is a foot in the door there and vice-versa.
What I DO know is the Head of our Virginia Chapter of The American Guild of Appraisers as well as the Number Two man from our HQ Chapter of AGA, OPEIU /AFL-CIO from Baltimore drove to the hearing about Coester in Virginia before the VaREAB today. I’ve also written over a half dozen or more blogs on various facets of the Coester “experience” , including one intended for the VaREAB and that states Attorney General wondering WHY state law is not being enforced?
It was WorkingRE (Mr. Isaac’s articles) that first brought this story to my attention. I forwarded the information to our guild HQ and they on VERY SHORT notice arranged to attend the meeting. I’m still waiting to hear the results as I write this .
I urge all of the above posters to research this AMC further, along with the NHVA. What happens in Virginia today WILL affect all of us.
In my research I noted it was Coester itself that first advertised flat rate national fees BACK IN 2013! They ignored complaints of Dodd-Frank violation by that policy back then. BEFORE North Carolina got a consent decree from them to pay reasonable fees. I was not able to open the links for the other complaints involving the other five states).
Since that time MANY AMCs were forced by competition (or greed) to adopt similar flat rate fees. It is now an industry “norm” among AMCs.
I contend it amounts to de facto price fixing. Even the small appraiser owned AMC I do QC consulting for keeps telling me THAT is why THEY cannot pay appraisers more. Now they at least (and one of their bigger, new potential clients) are open to cost-plus pricing which as we discussed really IS reasonable. That particular model involves $3,000 to $5,000 for small to medium sized commercial projects plus $500 for a technical desk review, plus $250-$300+- for the AMC as administrative overhead. It retains the fee structure their old appraisers are used to; establishes MEANINGFUL reviews, and compensates the AMC at what is intended to approximate 10% near the lower end of the anticipated range. It ALSO leaves room for exceptional assignments that simply don’t fit the normal pricing mold. I personally spoke with one of the bank representatives and can say first hand that we were in agreement as outlined. Whether we close the deal or not is subject to other normal requirements, but at least reasonable fees AND anticipated meaningful review costs are part of the basic pricing structure.
Again, kudos to WorkingRE; & Mr. Isaacs for their excellent research and reporting about this.
For ALL readers, THIS is why we need more than individual state coalitions (God Bless them!). VaCAP is among the best but even they have limits to what they can do or monitor nationally. Just as the AGA was present in the fight against California’s AB624; we are supportively engaged in Virginia’s efforts in this case. And are involved in so many other cases involving individual appraisers rights and complaints.
Join us at American Guild of Appraisers. We are NOT your typical union. As I said by way of introduction to TAF in Redondo Beach, I am a ‘center right, free enterprise, level playing field advocating Republican union organizer’ . My associates are equally independent thinking free enterprise advocates. But we ALSO believe free enterprise should be FAIR to all players. Contact me at (714) 366 9404 or janbellas@appraisersguild.org for more information.
-by John Jacob
We are a real estate appraisal company and actually did some appriasals for coestar back in 2009-2010. I ended up quiting doing appraisals for them because after I complained about the fee , I told them that they were breaking the Dodd- Frank law.
-I spoke with Brian coastar and found him short on personal diginity and management competance. I’m certain that he won’t be able to get into our state as an AMC as well. He actually has stated that he fills the low cost managment company position, which is admiting that they are against customary fees.
Hail to Virginia for turning them down. For the simple reason, they don’t want to pay appraisers in a timely manner. Go Virginia-go!
by Mike Ford CA AG; SCREA, AGA, GAA, RAA
http://mfford.com/html/c___r_fees.htm
For REASONABLE fees read the above. Hint its long-jump to the end and then backtrack.
-by Patricia Kizey
If anyone should be suing for restraint of trade it is the appraiser that should be suing the US Government for Dodd Frank.
-by Richard Hagar, SRA
May I suggest that all of these comments be sent to the management of Coester, “their” attorney, and the AMC “Association” that they are forming…. The CFPB might also find interest in these.
-by Wingfinger
The arguments presented by Coester’s defenders merely tell me that he runs precisely the sort of predatory AMC that needs to be shut down. These parasites have secretly abused their position as brokers of appraisal services, taking advantage of desperate appraisers in order to steal an absurdly unfair portion of the appraisal fee. At the very least their fee should be broken out from one paid to the appraiser. Not all AMCs are predatory, but these guys are clearly a cancer on the industry. I celebrate that they might finally be held accountable. Go Virginia!
-by Thomas I.M.
Lets face it when the HVCC was written it was flawed. Anthony Cumo in his infinite wisdom failed to state who was to pay the AMC fees. That little omission left it up to the lenders not to charge more for an appraisal. And left it up to the AMC to steal as much as they could from the appraisal fee. Why did this happen, lack of leadership in the appraisal profession. If the lender decides to raise their appraisal fees, the appraiser will not get a fee increase, it just puts more money in the pockets of the AMC’s. Isn’t it amazing that the AMC’s just take what they want out of the appraisal fee and give the appraiser the crumbs that are left. What we need is a revision of the HVCC to include a clause that the lenders pay for the AMC, as the AMC is hired by the lenders and that the AMC pay a full appraisal fee to the appraiser. These items should be paid with full disclosure to the client on the HUD 1. The HUD 1 is supposed to inform the borrower what they are paying per line item of the HUD 1, lumping together the AMC and the appraisal in one line may be a violation of HUD 1 rules and regulations. Fire the AMC’s and lets go back to the way business was prior to the HVCC. Basically business is the same as it was prior to 2009 except that the AMC’s are taking a big piece of the appraisers pie and appraisers are still being pushed to make the numbers or else.
-by Mike Ford CA AG; SCREA, AGA, GAA, RAA
Thomas there is much in what you say however realistically, we will never go back to how it was pre HVCC. Just won’t happen. In fact at least one large appraiser peer group anticipates treating / converting individual professional appraisal services to ‘commodities’ for the benefit of unknown foreign investor “clients” so far downstream that individual appraisals are not even considerations in buy / sell decisions.
Thomas what we should strive for are default MINIMUM “reasonable” fees as follows. They can be applied either nationally or by state. http://mfford.com/html/c___r_fees.htm
They are especially needed now that we have TURD (TRID)
-by Alfred@Baysong.com
Dodd-Frank is the LAW! Call your state and Federal attorney generals.
-State Boards cannot cave to these culprits. Our bi-annual registration fees
fund the state boards. They must take stand a stand against theses pricing policies.
The true mandate every appraisal organization must fight for is the appearance of the break-out of the appraisal fee on the HUD-1.
by Mike Ford CA AG; SCREA, AGA, GAA, RAA
My state’s website says it has no authority to enforce C&R appraisal fees which is odd because our State laws incorporate federal regulations too. California refers complaining appraisers back to CFPB.
CFPB should consider adopting a national MINIMUM rate to be paid to the appraiser-rather than ‘for’ the appraisal which includes AMC cuts. http://mfford.com/html/c___r_fees.htm
-by Larry Rhyder
Coestner is an idiot, and anyone who signs up with them are opening themselves up for examination by the DPOR. Even if he gets his license in Virginia they will be looking for an excuse to axe him and anyone who does appraisals for him. You’ll be seeing a story about him on “American Greed” before too long.
-by Rachel Massey
Powerful article Isaac, thank you for writing it.
My question is also, if C&R is $401, and the average AMC pays $328, isn’t that just simply an admission that the AMC doesn’t pay C&R? Also, what is the consumer actually charged? If it isn’t less than $401, it certainly can’t be seen as a win for the consumer.
-by Mike Ford CA AG; SCREA, AGA, GAA, RAA
All good points, but I’d start my challenge at the $401 fee being assumed to be C&R. “Average” fees paid by banks direct to appraisers are not necessarily any higher than AMC fees. A university study completed in 2014 necessarily includes rates that have been subjected to artificial below market competition ever since 2009 (HVCC); and that fail to differentiate between experience level of the appraiser or the complexity of the assignment.
Its a bit like asking starving people what their caloric intake is and then deciding that the average is ‘customary’ or ‘reasonable’.
“Reasonable” does not always follow “customary”. I offer the following instead.
http://mfford.com/html/c___r_fees.htm
-Jump to the end of the above article (final chart). Its based on Los Angeles so Virginia would have about a 10% lower final number. A non complex assignment by a very experienced licensed appraiser (Not certified) should be $585-10% = $526.50 SAY $525. Cross check it with or in comparison of fees from pre HVCC early 2009 adjusted for inflation to present.
by E.J. Brown
ALL HAIL VIRGINIA !!!
-by Mike Ford CA AG; SCREA, AGA, GAA, RAA
Enforcement efforts YES! C&R studies-not so much.
-by Joe Beaster
Boo Hoo Coestar, you’re not getting a fair share, so you are going to sue. Cry me a river, bunch of babies. Coestar pays what they say are reasonable fees? In 1993, the fee was $350, 22 years ago! Do the cost of living not go up in the Coestar world? In addition to paying late, which to an appraiser is salting the wound to an already low, low, fee, but don’t forget the ridiculous requests by unlicensed so called “appraisers” who couldn’t appraise their way out of a paper bag.
-If an appraiser does not comply with the state appraisal board, we lose our license. You did not comply, so quit yer bitchin. If you played by the rules from the beginning, you would not be in this predicament. Pay up in a timely manner and a reasonable fee, follow the rules (USPAP), be ethical or get the hell out of the appraisal business. In fact, here’s something novel, how about pay quick, within a week, pay ABOVE the nominal fee for just one week and look at the difference in quality, attitude, and responsiveness of the appraisers you use. Efficiency is profitable, but an appraiser knowing that he/she is getting a low fee, going have to deal with a list of issues, then not get paid in a timely manner? Buh bye Coestar, don’t let the door hit ya on the way out of Virginia, not gonna miss ya.
by Mike Ford CA AG; SCREA, AGA, GAA, RAA
Ditto!
-by William Gray
The whole problem is that Coester is of the opinion that the appraisal boards are in business to protect the appraisers which is not true. The appraisal boards are set up to protect the public. The appraisers have no protection!! We catch it from all sides!! At some point we will have to show some strength either through PAC’s or associations but it need to happen now!! With scope creep it takes much more time to complete an appraisal and everyone wants us to do it for less money! Is it a surprise that there is a shortage of appraisers now and it will only get worse!
-by Mike Ford CA AG; SCREA, AGA, GAA, RAA
William, Virginia has an active State Appraisers coalition. ALL states appraisers can also join the American Guild of Appraisers. You can read more about it at http://www.appraisersguild.org . We ARE a union, but not what the stereotype may infer. Our PRIMARY objective is to help appraisers. Guild senior leadership is all volunteer. Your dues do NOT go to pad someone’s high salary for sitting around and doing nothing. Our parent unions (OPEIU/AFL-CIO) are big enough to get things done.
-by Scott Runtzel
This section below REALLY makes me hope Coester is the loser in this case. If a borrower is buying a $300,000 home and pays $350 versus $450 for an appraisal the cost difference is .000333% in relation to the purchase price. And at $450 the appraiser can make a fair living if they do 4 to 5 per week.
Coester cites a 2014 Customary and Reasonable Fee report by Virginia Tech which states that the average fee for an appraisal ordered directly through a non-AMC client is $401, while the average fee for an appraisal ordered through an AMC is $328. Coester uses the Virginia Tech study to suggest that it helps keep fees low for the borrower because the appraiser is paid less when working through an AMC.
-