Fannie/Freddie appraisal requirements?

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LOFROMCO

58 Posts

Posted - 08/08/2008 : 12:58:15 PM

has anyone heard anymore on Fannie and Freddies attempt to force brokers to use national appraisal management companies instead of allowing us to order from independent local appraisers? Anyone have a take on what the future of that is?

LOFROMCO

58 Posts

Posted - 08/08/2008 : 1:25:40 PM

so no one has a take???? This will DESTROY everyone's ability to do refinances across the board, because you will get crappy appraisals from appraisers who don't even know your market.

bestbet123

1558 Posts

Posted - 08/08/2008 : 1:26:55 PM

This outta get good in a minute.

dtabar

748 Posts

Posted - 08/08/2008 : 1:27:36 PM

quote:
Originally posted by LOFROMCO

so no one has a take???? This will DESTROY everyone's ability to do refinances across the board, because you will get crappy appraisals from appraisers who don't even know your market.

The apraiser will more than likley be in your area. I don't see how an appraiser in New York can do the best job for an appraisal in LA. If that's the case, they might as wel use AVM's all day.

AGreene00

2796 Posts

Posted - 08/08/2008 : 1:27:51 PM

I'm gonna subscribe to this topic.

LOFROMCO

58 Posts

Posted - 08/08/2008 : 1:31:01 PM

I'm not talking state to state, I'm talking about some dooshbag in one city trying to accurately evaluate in another without knowing the market... I see it all the time

nutesch

433 Posts

Posted - 08/08/2008 : 1:34:52 PM

quote:
Originally posted by LOFROMCO

has anyone heard anymore on Fannie and Freddies attempt to force brokers to use national appraisal management companies instead of allowing us to order from independent local appraisers? Anyone have a take on what the future of that is?

That's a new one! I just heard they got rid of the 100% LTV No Doc Loans today also! How are we ever going to close a loan! LOL

LOFROMCO

58 Posts

Posted - 08/08/2008 : 1:39:54 PM

you don't have to be a smartass, I know that it's not "new news"... but there has been nothing more that has come out that says that this is GOING to be mandated, or what the final solution is.... The bottom line is, that GOOD appraisers are being screwed b/c they refused to let some management company take a portion of their fees and hide behind these companies to undervalue properties. Most of the appraisers that actually got on with these companies were green and stupid and that was the only way they could get business. Now the good ones can't even get on with these management companies because they are "no longer accepting applications"..... It's ridiculous.

kmikkola

774 Posts

Posted - 08/08/2008 : 2:18:43 PM

quote:
Originally posted by AGreene00

I'm gonna subscribe to this topic.

Looking to fill your mailbox?

powwow

377 Posts

Posted - 08/08/2008 : 6:22:25 PM

quote:
Originally posted by kmikkola

quote:
Originally posted by AGreene00

I'm gonna subscribe to this topic.

Looking to fill your mailbox?

When and if the HVCC goes into effect brokers will no longer be able to order appraisals (Scratch that. They can order one but they won't be able to use it.). It will have to be ordered by the entity funding the loan. Even the funding source will not be able to hand pick the appraiser. They will either have to order an appraisal through an AMC or start a department that orders appraisals. Basically, it's purpose will be to try to prevent anyone who benefits from the loan closing from hand picking the appraiser.

I don't think you will see appraisers from New York doing an appraisal on a property in California. In most cases, if not all, that practice would not be compliant with USPAP (sorry Moonrat). But you may see an appraiser from Atlanta doing appraisals in Columbus. Their are plenty of appraisers in most areas already signed up with these AMC's and it wouldn't make sense to send an appraiser an assignment in a market where they have little to no expertise.

millapps

106 Posts

Posted - 08/08/2008 : 7:58:06 PM

I don't think this law will pass:
a) There is too much protest against it.
b) What authority does the New York attorney general have to dictate national regulations?
c) Fannie Mae couldn't unilaterally enter into the agreement. It was regulated by the OFHEO.

However, I do think that more wholesale lenders (that don't use AMCs) will order the appraisals themselves after they receive the loan application and appraisal fees from the mortgage brokers. Those that use AMCs will eventually realize that in general, when the appraisers get paid crap, they write a crappy report.

powwow

377 Posts

Posted - 08/08/2008 : 8:06:09 PM

When it first came out I thought there was no way it would go into effect. But the longer it goes un-noticed the better chance I think it has. I can't believe that congress didn't address in the legislation they passed last week. Normally congress doesn't like being bypassed in that way. I give it 50/50 now. I'm sure the brokers' associations will challenge it in court, but FNMA and FHLMC can theoretically create and enforce their own guidelines. And thats the rub, Cuomo isn't dictating. FNMA and FHLMC agreed to it. Hasn't the OFHEO already come out in favor of the agreement?

TransNet

491 Posts

Posted - 08/08/2008 : 9:25:32 PM

quote:
Originally posted by powwow

When it first came out I thought there was no way it would go into effect. But the longer it goes un-noticed the better chance I think it has. I can't believe that congress didn't address in the legislation they passed last week. Normally congress doesn't like being bypassed in that way. I give it 50/50 now. I'm sure the brokers' associations will challenge it in court, but FNMA and FHLMC can theoretically create and enforce their own guidelines. And thats the rub, Cuomo isn't dictating. FNMA and FHLMC agreed to it. Hasn't the OFHEO already come out in favor of the agreement?

OFHEO isn't just in favor of the agreement, they are a party to it. And there are some serious legal issues regarding the way this agreement was crafted and the Administrative Procedures Act. Here are comment letters, all with reservations about the implementation of the HVCC. These aren't letters from trade organizations. These are comments from Federal regulatory agencies and if you read between the lines they're pretty pissed at the NYAg's end run around their authority. Not one of these agencies support the HVCC in its current form. There is no way this agreement is going to hold up in court.

OCC - http://www.appraisalinstitute.org/newsadvocacy/downloads/OCCLetter.pdf

OTS - http://www.appraisalinstitute.org/newsadvocacy/downloads/OfficeThriftSupervision_Letter.pdf

FDIC - http://www.appraisalinstitute.org/newsadvocacy/downloads/FDIC_OFHEO.pdf

OCC,OTS,NCUA & Fed Rsrve Brd - http://www.appraisalinstitute.org/newsadvocacy/downloads/OCC_OFHEO.pdf

FTC - http://www.appraisalinstitute.org/newsadvocacy/downloads/FTC_HVCC_Comment.pdf

Annemieke Roell

612 Posts

Posted - 08/09/2008 : 05:32:36 AM

In the meanwhile, the state of TN has come out against it and has declared it illegal.

I think the jury is still out on this one because good MB and lenders, who set their own high standards, are likely to suffer loss of quality with this "plan".

Bob H

282 Posts

Posted - 08/09/2008 : 06:36:47 AM

The market has already self regulated. Appraisals have never been scrutinized by underwriters as much as they are today. 4-6 comps and at least one active listing have become standard. I don't even remember what an appraisal with 3 comps looks like anymore.

The Code was drafted for a number of good reasons......all of which appear to have self corrected in the market. IMO- I doubt the Code will be enforced as drafted. Time will tell.

Mandyvilla

3050 Posts

Posted - 08/09/2008 : 07:32:56 AM

If banks don't go w/ AMCs (which is almost guaranteed if the lenders take over control from brokers - and possibly, correspondents?) they will all have to establish appraisal departments. What a potential trainwreck these new departments will be! Comes under the heading, tried that, got screwed by that, no more of that.

What happens is a mortgage company will hire someone that isn't even of processor quality, more like a set-up clerk or receptionist. Immediately, this/these individual(s) must order appraisals on something they know nothing about. I can see it now, contracts contingent on home inspections, getting appraisals ordered by mistake.....to conventional appraisals ordered on FHA, and it just keeps snowballing. But wait, there is more.........

Expected work flow comes in and the new appraisal desk cannot handle it, chances are they were never properly trained......Appraisal desk is a nightmare, so someone that needs to justify their fat salary reviews the process and comes up with this jewel -----> your request for an appraisal order will be kicked back to the processor or loan officer if the following is not included: each and every page of contract, addendum removing contingencies, and it just goes on and on, displacing responsibility from party A to party B. Typical bureaucratic BS.

So, the next step? LO's get around the BS by ordering the appraisal and then slipping the appraisal desk a copy of the order, and a note telling them the appraisal has already been ordered w/ so and so...and all has been sent to the appraiser. The desk loves it, less for them to do and the originations staff feels better too...and we are back to where we started.

Who was it that sang about going 'round in circles? Steve Miller? Get ready....this is gonna be fun. (not!)

powwow

377 Posts

Posted - 08/09/2008 : 08:01:39 AM

I agree with everybody that it will not go into effect in its current form but I do think the appraisal ordering portions of it will go into effect largely unchanged. Mainly because the appraiser/client relationship primarily between Appraisers anf Brokers is clearly broken. I can see the senario play out exactly like Mandyvilla says. That's why I think it's much more likely everyone would go the AMC route. They have software that is campatible with most of the mortgage software, so ordering an appraisal in most cases would just be pushing a button. Also, the AMC's are already adept at handling the large workflow. Not to mention that there is no expense to the lender if they go that route. No one to hire, and the AMC is paid by the appraiser.

Larger banks have already gone this route, and as much as I hate to say it, is probably the wave of the future.

Hopland

1969 Posts

Posted - 08/09/2008 : 2:01:07 PM

quote:
This will DESTROY everyone's ability to do refinances across the board, because you will get crappy appraisals from appraisers who don't even know your market

quote:
I'm talking about some dooshbag in one city trying to accurately evaluate in another without knowing the market... I see it all the time

quote:
they refused to let some management company take a portion of their fees and hide behind these companies to undervalue properties.

It's the notion by some that appraisals and appraisers are only good if they result in a favorable conclusion that has caused this mess. But the HVCC cure is probably worse than the symptom.

If you want to read more on the topic there are at least a dozen threads at appraisersforum.com in the "improving the profession" forum. You have to register.

http://appraisersforum.com/forumdisplay.php?s=&daysprune=&f=167

Mandyvilla

3050 Posts

Posted - 08/09/2008 : 5:16:02 PM

quote:
Larger banks have already gone this route, and as much as I hate to say it, is probably the wave of the future.

Absolutely the big guys are all heading towards AMCs. ~~Two of the largest lenders~~ The largest lender in the nation gave the word within the past week Retail may not under any circumstances speak to any appraisers or appraisal staff. All conversations are to occur between fulfillment and the AMC. I suspect the wholesale and correspondent staff will get the same word after they figure out how, when and where the consolidations will occur. Correspondents and brokers will be required to order appraisals via the end lender (so much for triple submits - however, it may pave the way for the appraisal to be universally accepted by other lenders). Other correspondents that don't know the end lender are already requesting each loan officer to turn in the 3 names for appraisers and the territories they cover. I would assume this would be companies the size of Suntrust, First Horizon, George Mason, Chevy Chase (yeah, I know that's quite a range, but they aren't the super-sized banks) and be very close to the old approved appraiser's list (lol and black list that no one will discuss).

What I don't understand: The appraiser's on AF are the closest you can come to a national group. Why haven't a group of you banned together and formed your own AMC? Getting the right people is the biggest challenge, finding appraisers for each job is the second. The QA is showing that the originating lender has zero control or input on the appraisal or order. Meanwhile....everyone snoozes and watches and waits for January 1 to roll around. It's not like you need to invest a lot into this, legal is your biggest bill, and aren't there some attorneys on AF? Or is it legal to barter expert testamony in exchange for legal advice? Wouldn't you rather pay "one of your own" the overhead to run an AMC? Just think, a way to show the world how it's down, any way YOU want it. You want to even leave the name of the client off the appraisal until the job it done? Think of the possibilities.

I hate to say it, but the battle for appraisal independence from expected results on the order has backfired, and backfired in a big way. Everyone in the lending world is exhausted from other battles (Nehemiah, guideline and program deletions) and is feeling real beat up about now over being considered slime of the universe. I can't see anyone taking up the appraisal cause from our team. The whole scenario makes me sick. But are you really going to give up the battle that easy?

ritabradley01

2901 Posts

Posted - 08/09/2008 : 5:41:40 PM

There's some stuff in the works I think. Pam and friends are cookin' something up.

David Wimpelberg

88 Posts

Posted - 08/10/2008 : 04:20:46 AM

quote:
Originally posted by Mandyvilla
What I don't understand: The appraiser's on AF are the closest you can come to a national group. Why haven't a group of you banned together and formed your own AMC?

The AMC was a disaster before, is now, and will continue to be in the future. Even if a "better" one came on the scene. A cut still will be taken out of the the appraiser's fee...that's just the fact of the having a middleman.

For most that have a diversified client base, it's a waste of time. There is no reason for many of us to deal with middleman, nor give them any cut of our fee...thus no reason to set up some entity that will do just that.

Mandyvilla

3050 Posts

Posted - 08/10/2008 : 05:08:00 AM

What I find very disturbing is the newly licensed or certified among your ranks are discouraged by their peers and mentors to work for AMC's, when like many, they just need to provide food and shelter, or the 2nd PT income. While the AMC may have been a disaster for you, I am willing to bet you had a mentor to take you under their wing. Why presume that someone just starting out cares about $350 vs. $300, when what they really care about is steady work? Yes, I have seen some of the $170 references, but there are just as many that doen't shave that much off. Are any of the anonymous appraisers willing to post which AMCs pay substandard pay? (w/ proper CYA verbiage, of course).

As for the diversified client base, I am reading many are not as fortunate. It reminds me of the deer in the headlights syndrome. Startled, not moving. Then when they do, it's in a panic. Rather than just hang all day online, try a proactive approach, even if just for a specified locality and one small to mid-size lender. Many won't move - waiting to see if it really happens. The memos and directives we are seeing are fairly ominous. I think if legislation doesn't occur, the radical changes will still move forward. We won't see the order comfort zone in 2009.

I just see a win-win opportunity....the chiefs at the AMC can act as reviewers.....train the young pups "their" way and set the standards for the industry. Or, they can sit around all day and talk about the business they don't have. You are in the mind set of the appraiser of yesterday and yesterday isn't coming back - and I suspect those are the appraisers that must diversify or leave the industry. The same ones that need to pick up a copy of "Who moved My Cheese." The door has been opened and we can't shove the beast back where it came from. Our way of doing business has been changed forever.

Hopland

1969 Posts

Posted - 08/10/2008 : 07:58:06 AM

quote:
Yes, I have seen some of the $170 references, but there are just as many that doen't shave that much off.

No, there are not just as many that don't shave of that much. Almost all will take half of the fee or even more unless they just can't find an appraiser willing to work for those fees, and they shop relentlessly.

They are treating the appraisal as though it were a commodity instead of the custom product that it is. And as the real estate markets get worse and worse each appraisal is a new excercise in pain. Lenders require more and more detailed analysis and reporting but there are fewer and fewer sales to work with and increasing levels of "market noise" caused by REO and foreclosure activity. Completing appraisal work under these conditions takes more time and a lot more experience but lenders are demanding faster turn times and lower fees. And then AMC's want their cut too, and almost always an unreasonable cut given what little value they add. The only appraisers attracted to these fees are the least qualified to do the work.

I have worked for most of the major AMC's and continue to work with several. But I'm in a rural area and there is not a lot of competition and most of the idiot appraisers who used to come up here at lowball fees have either gotten out of the business or realize how difficult and time consuming this area can be. Therefore, I can continue to do my work at acceptable fees. God know what the borrower is paying on their HUD1.

Annemieke Roell

612 Posts

Posted - 08/10/2008 : 08:22:04 AM

quote:
Originally posted by Hopland

[quote]

I have worked for most of the major AMC's and continue to work with several. But I'm in a rural area and there is not a lot of competition and most of the idiot appraisers who used to come up here at lowball fees have either gotten out of the business or realize how difficult and time consuming this area can be. Therefore, I can continue to do my work at acceptable fees. God know what the borrower is paying on their HUD1.

Same here ..... we have several AMCs as a client but at out full fee only. And in some cases, our full fee has a PITA surcharge. We don't get a LOT of work from them but enough.

Speaking of rural appraisers .... one of the State Representatives introduced a bill that would require every certified appraiser (licensed appraisers can no longer take on trainees in OK since the skipy mill incident) to take on at least 1 trainee. His reasoning was that one of his constituents, a trainee, could not find a rural appraiser to take him on, so the logical conclusion was that there aren't enough rural appraisers so we should be forced to train more.

The fact of the matter is that my office will do rural appraisals all day long, but not for bottom fees.

The time and cost involved in a rural appraisal is such that the fees are naturally higher. But most AMCs are not willing to pay those fees.

Mandy .. regarding appraisers oranganizing into an AMC ...... appraisers are difficult to organize. Ever tried to herd a bunch of cats??

Annemieke Roell

612 Posts

Posted - 08/10/2008 : 08:35:55 AM

Just had another thought on the matter .....

quote:
I just see a win-win opportunity....the chiefs at the AMC can act as reviewers.....train the young pups "their" way and set the standards for the industry. Or, they can sit around all day and talk about the business they don't have. You are in the mind set of the appraiser of yesterday and yesterday isn't coming back - and I suspect those are the appraisers that must diversify or leave the industry.

You are right and several of us have been and are still toying with this concept. For example, a handful of us have formed a "coalition" which is reflected in our website. The quality, national mortgage clients that we have now have a choice to go to selected other states/regions and hire an appraiser from our coalition and KNOW that this appraiser is good because otherwise my company would not have added them to our website.

Unfortunately, not is this process very slow because of lack of time and capital to set it up properly, but it takes time for it to trickle through. However, the feedback we have had from clients so far as been 100% positive. And ours is not a AMC .... we do not collect any fees.

In an ideal world there would be 1 central AMC with only top notch appraisers. But until the quality appraisal requirements of the indivisual states has been raised (or we have a nationally run Appraisal Board only)we will never be able to seperate the good ones and run the skippies out of business .....

Slag

2 Posts

Posted - 08/11/2008 : 12:35:47 AM

Of the various examples of dissatisfaction over HVCC from the powers that be, I think the letter at the link below carries more weight than many I've seen. If you read it like I do, with great gnashing of teeth, bulging eyes and clinched colonic musculature, you might even call it a smack down.

See here:

http://www.tavma.org/images/HVCC_Comments/regulators_jointletter_hvcc.pdf

It is a joint letter signed by:
- Randall Kroszner (Board of Governors of the Federal Reserve System )

- John Reich (Director of the Office of Thrift Supervision)

- John Dugan (Comptroller / Comptroller of the Currency)

- JoAnn Johnson (Chairperson of the National Credit Union Administration)

Slag

2 Posts

Posted - 08/11/2008 : 12:40:03 AM

Well, it looks like you will have to do a cut&paste if you want to view the document. The website with the letter appears to be (logically) blocked by Broker Outpost.

Lawrence R.

80 Posts

Posted - 08/11/2008 : 06:25:38 AM

HVCC is dead on arrival, it will be a closed casket funeral. One or two of the provisions will be implemented by a rose with any other name...

AMCs suck and I love all the full fee AMC appraisers that visit here, but I can tell you that I have quoted my full fee(from 300 to 375 on varying times) to probably 75 different AMCs on over 200 occasions
9initiated by the amc), and gotten not one single order. Rural or standard, not one order.

For the most part, the only people who do steady, day in day out work for AMCs are the bouchedags(bleep that!) from the next town over.

The proliferation of AMCs and their BS will almost GUARANTEE you to get the kind of appraiser you don't want.

David Wimpelberg

88 Posts

Posted - 08/11/2008 : 06:30:55 AM

quote:
Originally posted by Mandyvilla
You are in the mind set of the appraiser of yesterday and yesterday isn't coming back - and I suspect those are the appraisers that must diversify or leave the industry. The same ones that need to pick up a copy of "Who moved My Cheese." The door has been opened and we can't shove the beast back where it came from. Our way of doing business has been changed forever.

Actually, yesterday is coming back...in a big way.

One of the biggest problems is that many of the fundamentals were eviscerated. Things like education and competency are going to be important going forward, just like they were in the past.

powwow

377 Posts

Posted - 08/11/2008 : 06:40:52 AM

quote:
Originally posted by Lawrence R.

HVCC is dead on arrival, it will be a closed casket funeral. One or two of the provisions will be implemented by a rose with any other name...

AMCs suck and I love all the full fee AMC appraisers that visit here, but I can tell you that I have quoted my full fee(from 300 to 375 on varying times) to probably 75 different AMCs on over 200 occasions
9initiated by the amc), and gotten not one single order. Rural or standard, not one order.

For the most part, the only people who do steady, day in day out work for AMCs are the bouchedags(bleep that!) from the next town over.

The proliferation of AMCs and their BS will almost GUARANTEE you to get the kind of appraiser you don't want.

I guess I'm lucky. 100% of my AMC work comes from Suntrust and First Horizon, via AppraisalPort, and it is all at full fee plus the handling fee. These companies went to AppraisalPort over a year ago. In FHHL's case almost three years ago. They didn't do it for the same reasons most do, lower fees. They did it because they saw the comming crisis and wanted to be out front. Their balance sheets bear out their wisdon.

Lawrence R.

80 Posts

Posted - 08/11/2008 : 07:34:59 AM

quote:
Originally posted by powwow

quote:
Originally posted by Lawrence R.

HVCC is dead on arrival, it will be a closed casket funeral. One or two of the provisions will be implemented by a rose with any other name...

AMCs suck and I love all the full fee AMC appraisers that visit here, but I can tell you that I have quoted my full fee(from 300 to 375 on varying times) to probably 75 different AMCs on over 200 occasions
9initiated by the amc), and gotten not one single order. Rural or standard, not one order.

For the most part, the only people who do steady, day in day out work for AMCs are the bouchedags(bleep that!) from the next town over.

The proliferation of AMCs and their BS will almost GUARANTEE you to get the kind of appraiser you don't want.

I guess I'm lucky. 100% of my AMC work comes from Suntrust and First Horizon, via AppraisalPort, and it is all at full fee plus the handling fee. These companies went to AppraisalPort over a year ago. In FHHL's case almost three years ago. They didn't do it for the same reasons most do, lower fees. They did it because they saw the comming crisis and wanted to be out front. Their balance sheets bear out their wisdon.

On your testimonial, I just signed up with appraisalport. We shall see...

Hopland

1969 Posts

Posted - 08/11/2008 : 07:56:39 AM

My AP clients pay full fee. The AMC's I work with would rather not pay full fee but they will if they can't find someone else. Since the only AMC order's I accept are full fee then that means that the AMC's I do business with pay full fee. LOL. I can't do the work properly and still make a profit for anything less than I charge.

powwow

377 Posts

Posted - 08/11/2008 : 07:56:42 AM

quote:
Originally posted by Lawrence R.

quote:
Originally posted by powwow

quote:
Originally posted by Lawrence R.

HVCC is dead on arrival, it will be a closed casket funeral. One or two of the provisions will be implemented by a rose with any other name...

AMCs suck and I love all the full fee AMC appraisers that visit here, but I can tell you that I have quoted my full fee(from 300 to 375 on varying times) to probably 75 different AMCs on over 200 occasions
9initiated by the amc), and gotten not one single order. Rural or standard, not one order.

For the most part, the only people who do steady, day in day out work for AMCs are the bouchedags(bleep that!) from the next town over.

The proliferation of AMCs and their BS will almost GUARANTEE you to get the kind of appraiser you don't want.

I guess I'm lucky. 100% of my AMC work comes from Suntrust and First Horizon, via AppraisalPort, and it is all at full fee plus the handling fee. These companies went to AppraisalPort over a year ago. In FHHL's case almost three years ago. They didn't do it for the same reasons most do, lower fees. They did it because they saw the comming crisis and wanted to be out front. Their balance sheets bear out their wisdon.

On your testimonial, I just signed up with appraisalport. We shall see...

Please let me know how it works out. I've always been interested how it goes for someone who didn't already have a client when they signed up. You may even give them a call and see if they have any clients who are looking for appraisers. I have heard that this has worked.

powwow

377 Posts

Posted - 08/11/2008 : 08:00:38 AM

quote:
Originally posted by Hopland

My AP clients pay full fee. The AMC's I work with would rather not pay full fee but they will if they can't find someone else. Since the only AMC order's I accept are full fee then that means that the AMC's I do business with pay full fee. LOL. I can't do the work properly and still make a profit for anything less than I charge.

Right on Hopland. This job has become too time consuming to do correctly to work for anything less. I've actually heard tell of runners doing 1004's for a split of $170. I bet that's a reliable report. Besides I have a honey-do list a mile long to work on if the full fee stuff doesn't come in.

Annemieke Roell

612 Posts

Posted - 08/11/2008 : 08:29:21 AM

quote:
Originally posted by powwow

quote:
Originally posted by Hopland

My AP clients pay full fee. The AMC's I work with would rather not pay full fee but they will if they can't find someone else. Since the only AMC order's I accept are full fee then that means that the AMC's I do business with pay full fee. LOL. I can't do the work properly and still make a profit for anything less than I charge.

Right on Hopland. This job has become too time consuming to do correctly to work for anything less. I've actually heard tell of runners doing 1004's for a split of $170. I bet that's a reliable report. Besides I have a honey-do list a mile long to work on if the full fee stuff doesn't come in.

I have heard from staff appraisers for a company we shan't mention who are doing rural, complex appraisals on 2500+ sf houses for $175. NUTS.

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