Capital Valuations · An appraiser’s perspective
AMC Reform: Why I Want Lenders to Work Directly With Appraisers
Originally published
Updated
I want lenders to work directly with appraisers because the AMC system has made my work harder to sustain. Since I first wrote about reform, low fees, rising expenses, and constant interruptions have left me questioning whether I can stay in this business.
I have more than 20 years of appraisal experience. I should be able to spend that experience solving appraisal problems, earn a fee that supports the work, and deliver the report we agreed on. Instead, too much of my day feels like a fight over whether the work deserves to be paid for in the first place.
An appraisal management company, or AMC, sits between the lender and the appraiser to arrange and administer assignments. This update is about what that relationship feels like from my side of the desk—and what I want lenders and Virginia regulators to change.
Same old fees. Higher costs.
I remember management portions of roughly $75 to $100 years ago. That is my recollection from working in the business, not a historical fee survey. Today, I see situations where a much larger share of the borrower’s charge never reaches the appraiser. Meanwhile, my software costs keep going up.
My floor is $400. I generally receive about $400 to $450, and even getting that can be a struggle. To me, those fees feel stuck around what appraisers were earning 20 years ago. My business costs have not stood still.
When I bid $400, my rough estimate is that I lose the assignment about nine times out of ten. I do not see the winning bids, so I cannot say exactly what another appraiser accepted. What I can say is that holding my fee where I believe it belongs costs me work.
- Offered to the appraiser
- $350 51.5% of the total
- Difference
- $330 48.5% of the total
That example captures why I am angry. The borrower can pay a substantial appraisal charge while the person responsible for doing the appraisal is pushed to accept far less. My separate guide to AMC fees explains the borrower’s side of that distinction.
Could I lower my fee another $25 and possibly get more assignments? Maybe. But I have to draw a line somewhere. More orders do not solve the problem if I have to keep giving away what the work is worth to get them.
Low AMC fees follow me into private work
The problem follows me when I quote a homeowner directly. People ask a real estate agent what an appraisal costs, or ask an appraiser what they get paid. Then that number becomes what they expect to pay.
How do I explain a $700 or $800 private appraisal fee when the number they have in mind is $400 or $450? The assignment may justify the higher fee, but I am starting the conversation at a disadvantage. That is the bind I feel caught in.
Depending on the assignment, I believe appraisal work should command $800 to $900. That is my view of what the work can warrant, not a market survey or a price for every house.
The new UAD 3.6 reporting system adds to my concern. We are expected to adapt to new tools and requirements while the fee discussion stays stuck in the past.
Constant calls interrupt the work
I also deal with tight deadlines and repeated requests for updates before the deadline has passed. An order arrives. A few hours later, someone asks whether I have made the appointment. Then come overnight emails, another message the next morning, and sometimes a call on top of that.
I have had those emails arrive around 3 a.m. During the workday, I can have three reports in front of me while several management companies call, sometimes more than once. Every interruption pulls me out of the report I am trying to finish. On affected days, I estimate the disruption can consume half an hour to an hour. That is my estimate, not a time study.
We agreed on a fee and a deadline. Let me do the work.
I want the agreement to mean something. If there is a real issue with access, scope, or delivery, address it. But repeatedly asking for the same status while I am still working within the agreement does not help me complete the appraisal. It adds another task to an already underpaid assignment.
What Virginia’s fee rules actually say
Virginia requires AMCs to follow federal customary-and-reasonable compensation rules. For covered transactions, the fee must fit comparable appraisal work in the local market. An appraiser accepting a fee does not, by itself, prove that the fee meets the rule. [1] [2]
Virginia’s appraiser board recognizes the Veterans Affairs fee schedule as one way an AMC can show it meets the compensation standard. Another compliance method is also allowed. That makes the schedule a recognized benchmark, not a mandatory minimum for every assignment. [3]
But who makes those protections matter?
To me, the way customary-and-reasonable fee protection works in practice has become a joke. I keep facing fees I believe are inadequate. I do not feel protected as a working appraiser.
The AMC wants to pay less. It also gets to defend that amount as reasonable. From where I sit, the bidding process keeps coming back to what someone will accept, while the work stays the same.
The law does not give an AMC unrestricted authority to declare any accepted bid reasonable. The problem I want examined is whether its justification actually satisfies the standards—and whether enforcement makes those standards matter in everyday assignments. [1]
I want Virginia’s appraiser board to explain how it checks fees, what happens to complaints, and what it does when a company breaks the rules. I believe its handling of fee protection deserves legal scrutiny. Appraisers need results they can see in their working lives.
Big companies. Small appraisers.
The business feels increasingly corporate to me, while I am still the small appraiser trying to make the numbers work. I remember one or two appraiser-run management companies I liked years ago. I do not know what happened to them, and I will not pretend I know whether they were bought or closed.
There are documented examples of investment backing and organized advocacy. Gridiron Capital lists AMC Class Valuation as a portfolio investment. REVAA describes its role as advocating for the residential valuation industry on public-policy issues. [6] [7]
My concern is the imbalance in influence. Large businesses can defend their model while the individual appraiser is trying to finish reports and hold onto a workable fee. I want lenders and regulators to give the person doing the valuation work a much stronger voice in how this system operates.

Lenders can work directly with independent appraisers
Fannie Mae does not require lenders to use an AMC. Its guidance permits ordering through an individual appraiser, an appraisal company, or an AMC, with independence requirements governing the process. Selection must remain insulated from loan-production influence. [8]
That is why my message to local mortgage companies is direct: take responsibility for the relationship with your appraisers. I want lenders to build a process that pays the person doing the work appropriately and gives that person room to complete it.
Direct engagement still needs controls that protect the appraiser’s conclusions. A lender can maintain an independent selection and oversight process without routing every assignment through an AMC. [8]
The changes I want lenders and regulators to make
If I could redesign the system, I would remove AMCs from the lender-appraiser relationship. That is my position. I also want meaningful compensation protection and basic respect for the agreement under which an appraiser accepts an assignment.
Engage appraisers directly
Build lender relationships with qualified appraisers, with independence controls around selection and conclusions.
Make fee protection enforceable
Develop a regional minimum-fee framework through public policy, supported by independent research and adjusted for complexity and scope.
Respect the assignment agreement
Agree on the fee, scope, deadline, and useful update points. Give the appraiser time to do the work.
A minimum-fee framework is a reform I want considered, not a description of a universal minimum that exists today. I want a defensible standard based on the market and the work, with enforcement that appraisers can see and understand.
This has become serious enough that I have considered leaving the business. I do not think lenders should dismiss that as an appraiser complaining about one bad order. Experienced people have to be able to afford to keep doing this work.
To the lenders here in Hampton Roads: look at what the appraiser actually receives. Look at how your process uses that person’s time. Then ask whether you are supporting the professional you depend on to deliver the appraisal.