According to appraiser David Smith, AMCs just need to be told to do their job.

“When an AMC receives a request from a lender for more information, BANG, it is immediately forwarded to the appraiser for correction without the AMC reviewing the legitimacy of the lender’s request,” says Smith (not his real name). “I often wonder if appraisers realize the function of an appraisal management company. These companies continue to eat into the revenues of appraisers while professing to provide a valuable service to lenders by improving the quality of the reports. Yet, they are far from providing this service. The lack of responsibility by AMCs to truly manage the process is also a failure to provide the appraiser with independence as required by law,” says Smith.

Smith wonders why appraisers let themselves be pushed around when both state and federal law is on their side- at least in North Carolina. “Lenders and AMCs continue to request additional comps and appraisers continue to waste time by providing them, afraid they will lose work,” said Smith. “What many appraisers may not realize is that it is their responsibility to establish the Scope of Work, not the AMC. This should always take place prior to accepting any assignment and should include the number of comps that will be provided in the report. Certifications in appraisal reports include statements by which the appraiser ‘certifies’ that he or she has ‘selected and used comparable sales that are locationally, physically, and functionally the most similar to the subject property.’ Lenders and AMCs requesting additional comps should be directed to the Appraiser’s Certification, Item 7 (1004 forms) and the Scope of Work. The question I pose when asked for additional comps is, why would you want comps which I obviously think are less reliable than those already provided?”