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Fighting for Fairness: Appraisers Deserve Better from AMCs and the System That Enables Them
by Paula Konikoff, President of the Appraisal Institute
For too long, residential appraisers have been left to navigate a system stacked against them—pressured by appraisal management companies (AMCs), underpaid for their work, and constrained by a regulatory framework that often puts them last. At the Appraisal Institute, we’ve been working to change that for many years.
We’ve stood up for appraisers in their day-to-day interactions with AMCs—calling out low-fee “cramdown” practices, pushing back on unrealistic turn times and advocating for stronger oversight of an industry that operates with far too little accountability. AMCs were created to add independence to the valuation process, but too often they’ve added inefficiency and inequity instead.
The Appraisal Institute has led the charge to require consumer disclosure of AMC fees. When a borrower pays for an appraisal, they should know how much of that fee goes to the licensed appraiser and how much is taken by an AMC. Hiding that breakdown misleads consumers and devalues the role of the appraiser. We started this cause and carry it forward today. Just last week at our Legislative Day and Leadership Development conference, our members lobbied Capitol Hill on this very issue.
And we are not new to this fight.
As far back as 2009, the Appraisal Institute testified before Congress in support of appraisal reforms included in the Mortgage Reform and Anti-Predatory Lending Act (H.R. 1728). Our testimony outlined the need for registration and oversight of AMCs, clear separation of appraisal and management fees, and strong protections for appraiser independence. We raised alarms about the risks of unregulated broker price opinions and automated valuation models replacing professional appraisals, concerns that are even more relevant today.
That testimony helped lay the foundation for the Dodd-Frank Wall Street Reform and Consumer Protection Act, which followed in 2010. Many of the provisions the Appraisal Institute advocated for—customary and reasonable fees for appraisers, AMC registration, consumer disclosure of AMC fees and protections against conflicts of interest in the use of AVMs—were codified in federal law as a direct result of this groundwork.
That testimony also called out the business model of many AMCs that “cram down” appraiser fees to boost profits at the expense of quality and consumer protection. We warned of regulatory loopholes, weak enforcement and conflicts of interest that put appraisers and consumers at risk. And we called for robust reforms to ensure that appraisers are treated as the highly trained professionals they are rather than an afterthought in the mortgage process.
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Even before Dodd-Frank made AMC regulation mandatory, the Appraisal Institute was the only organization to lead the movement for meaningful oversight of AMCs. We developed model legislation that became the basis for most state laws governing AMC registration and conduct years before federal law required states to act. Our leadership filled a regulatory vacuum that had left appraisers and consumers exposed, and the legislative framework we helped create remains the foundation of AMC oversight in the majority of states today.
Today, that same leadership is being applied to a new and growing risk: unregulated property data collection. Once again, the Appraisal Institute is at the forefront of drafting model legislation to ensure proper oversight of property data collectors and the companies that deploy them. Our model law establishes licensing, training, background checks and accountability standards, and it is already serving as the foundation for legislation, which is now under consideration in several states. Just as we did with AMCs more than a decade ago, we are building the regulatory framework needed to protect the public and preserve the integrity of the valuation process.
While appraisal waivers are currently being used in approximately 17 percent of transactions—mostly in low-risk scenarios—the Government Sponsored Enterprises (GSEs) have the ability to dramatically expand that share, as they did during the COVID-19 pandemic when waivers were granted in roughly 50 percent of transactions. We’ve seen firsthand how quickly the scope of these policies can grow, and we continue to caution against a future where the use of waivers and hybrids becomes the norm rather than the exception. Our position is clear: Credentialed appraisers must remain at the center of the valuation process, not sidelined by automated decisions or fragmented assignments driven by cost and convenience and to the detriment of consumers.
We remain on the front lines engaging with policymakers, testifying before regulatory bodies and working in coalitions to ensure appraisers are treated fairly and professionally. Our commitment is to our members, the integrity of the profession and the end consumer.
It’s time to restore balance. AMCs must be held accountable. Appraisers must be compensated fairly. And consumers must be informed. At the Appraisal Institute, that’s long been our mission, and we remain committed to it.
Sincerely,
Paula Konikoff
2025 President, Appraisal Institute
About the Author
Paula K. Konikoff, JD, MAI, AI-GRS of Los Angeles, is the 2025 president of the Appraisal Institute. As president, she serves on AI’s Executive Committee and chairs the policy-setting Board of Directors. She was instrumental in the creation of the Women’s Initiative Committee. She is also the author of the book, Appraisers in Arbitration.
OREP Insurance Services, LLC. Calif. License #0K99465
by Robert S. Abbott
With all due repsect Paula, I’ve been appraising for 27 years and the first time I heard the AI advocating for residential appraisers was under Cindy Chance’s brief tenure. It actually had me considering applying for my SRA and joining the AI. Unfortunately the other leadership at the institute has ruined that and I honestly do not know what it would take for you to regain my support and trust.
-by John E. Evans
I agree with the comments posted above. I stopped appraising because the appraisal orders were given to the lowest bid with unreasonable turn times! Please provide the concrete evidence that the appraisal business of completing lender appraisal requests through AMC’s has improved since 2009.
-by Mr. Cortney B Strother
There is none.
-by Gerard Hayes
This article is a joke, right? AMC’s are worse than than ever. If getting appraisers treated fairly is their long term mission why hasn’t it happened?
-by Mr. Cortney B Strother
I haven’t done an AMC job in over 4 years … and I won’t in the future either. I strictly do private and/or direct panel work only. Note to the powers that be, there are plenty of us out here that are available for work … but not for fees that I was charging 27 years ago when I started. Get your act together, or suffer the consequences.
-by Thomas Cahill
Although you indicate the AI has been fighting for appraisers regarding AMC fees and turn times since 2009 what have you accomplished. Fees are still very low, turn times are short, there has been no headway on the fee disclosure and appraisers are still suffering.
-by Mr. Cortney B Strother
This article is a total smokescreen and loaded with empty promises in order to deflect attention away from the fact that the AI is the subject of a fraud investigation pertaining to their testing practices. With all of this espoused grandstanding about being at the “forefront” of standing up for appraisers for the past two decades … have you actually seen any changes? … NOPE! … I certainly haven’t. AMC’s have only gotten WORSE (not better) with regard to their grift of appraiser fees. Still no disclosure of separation of AMC fees and appraiser pay in closing documents … still no enforcement of “customary and reasonable” fees for appraisers … still no enforcement of reasonable turn times … etc., etc., etc. This article is a joke … except it’s not funny.
-by steve ward
Disclosing fees to the borrower? To what end? This is a fools errand and a waste of time and resources. How on earth will the create fair fees and turn times? Regulate fees paid to the appraiser and stop the bid process for work.
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