Home/Field Notes/AMC fees and 3.6
The move to UAD 3.6 added close to 94 percent more fields to a lender appraisal. The offered fees have not moved. Here is what that arrangement looks like from the inside, and why it matters to the homeowner who paid for it.
Published September 2026
When a lender orders an appraisal on your house, you do not choose the appraiser. In most cases the lender does not either. The order goes to an appraisal management company, and the AMC distributes it to appraisers on its panel — frequently by broadcasting the assignment and giving it to whoever accepts first, or accepts cheapest.
You pay for that appraisal. It appears on your closing disclosure as a line item. But it was not developed for you, you are not the client, and the fee you paid is not necessarily the fee the appraiser received.
That arrangement has been in place for years. What is making it visible right now is a form change.
The industry is moving from the legacy UAD 2.6 forms to UAD 3.6 and a single redesigned report. I have written separately about the mechanics and the timeline; the short version is that the old form set is being retired in favour of one dynamic, data-first report.
The practical effect on the person doing the work is that there is a great deal more of it. One of the software vendors building for the new standard puts it at roughly 94 percent more fields to complete when a 2.6 report is converted to a 3.6. That figure comes from the people writing the software rather than from a regulator, and I pass it along as their estimate, but it matches what appraisers are describing. There is new data to collect, new software from new providers, and a new set of portal and delivery quirks to absorb while everyone learns the system at once.
Reports from appraisers completing their first 3.6 assignments have ranged from ten to sixteen hours. That number should fall as familiarity grows and the software matures. Right now it has not fallen yet.
A recurring complaint is that assignments are being ordered as “traditional” appraisals. The appraiser reasonably reads that as a 2.6 assignment, quotes accordingly, and begins the work. Partway through — in some cases after delivery — they are told the file is a 3.6 and must be produced on the new form.
The fee does not move. The work roughly doubles.
This is not a matter of professional courtesy. It is written into statute.
Under 15 U.S.C. §1639e(i), lenders and their agents shall compensate fee appraisers at a rate that is customary and reasonable for appraisal services performed in the market area of the property being appraised. An appraisal management company acting for a lender is an agent. The same statute says the evidence for such rates may be established by objective third-party information — government agency fee schedules, academic studies, and independent private sector surveys.
So the standard is not what a panel will accept. It is what is customary and reasonable in the market area, measured against outside evidence.
The implementing regulation, 12 CFR §1026.42(f), is more specific, and it is worth reading closely because it answers the question people usually ask me next.
A lender or its agent earns a presumption of compliance under §1026.42(f)(2) by paying an amount reasonably related to recent rates for comparable work in the market, and by reviewing certain factors in setting it. The regulation names them: the type of property, the scope of work, the time required, the appraiser’s qualifications, their experience and professional record, and the quality of their work.
Two of those factors are scope of work and time required. Set that beside a transition that adds close to double the fields and, for now, roughly doubles the hours. I am not going to tell you what conclusion to draw. I am telling you which factors the regulation says have to be reviewed.
The same paragraph attaches a condition. The presumption of compliance holds only where the lender and its agents do not engage in anticompetitive acts affecting appraiser compensation — the regulation gives conspiracies to restrain trade “through methods such as price fixing or market allocation” and acts of monopolization as its examples. Those are the regulation’s words, in a provision about when the safe harbour is unavailable. I am quoting them because they are there, not because I am in a position to say that any particular company has done any particular thing. That is a determination for a regulator or a court on evidence, and I have neither.
There is one more provision that gets very little attention and probably deserves the most. A lender may also establish compliance under §1026.42(f)(3) by relying on objective third-party information — fee schedules, studies, surveys. But §1026.42(f)(3)(iii) requires that such a survey exclude compensation paid to fee appraisers for appraisals ordered by appraisal management companies.
Read that again. When the regulator sat down to define what a customary and reasonable fee looks like, it wrote AMC-paid fees out of the evidence. What panels pay was not treated as proof of the market rate. It was treated as the thing the market rate has to be measured against from the outside. That judgment was made in 2013, and it has been sitting in the Code of Federal Regulations ever since.
15 U.S.C. §1639e(i): lenders and their agents shall compensate fee appraisers at a rate that is customary and reasonable for appraisal services performed in the market area of the property being appraised.
An appraiser I know was offered $450 for a 3.6 assignment. When he declined, he was told that nobody is raising their fee and he should take it at that number. He declined again. The assignment went to someone else within the hour.
I can speak first-hand to the lower end of this. Broadcast offers arrive in my inbox regularly, and foreclosure and REO assignments come across as low as $350. I do not accept them, so I cannot tell you what those files end up costing anyone downstream. I can tell you the number that was offered to me, because I still have the emails.
What the borrower pays is a separate number, and you do not have to take my word for any of it. The appraisal fee is an itemised line on your Closing Disclosure, on page 2. Homeowners have told me what they found on theirs. Rather than repeat a range I collected second-hand, I would rather you pull your own document and read the line yourself, because that number is specific to your file and mine would only be an average.
Whatever it says, the difference between that figure and what reached the appraiser stays with the management company, and in some arrangements a separate delivery or technology fee is deducted from the appraiser’s side as well.
I am reporting what is being offered. The other half of the arithmetic is on your closing disclosure, and you can do the subtraction without any help from me.
When an assignment is distributed to whoever accepts the lowest number, the selection is on price rather than on suitability. That is not a criticism of any individual appraiser, and plenty of good work gets done at unglamorous fees. But as a system it selects predictably: the appraisers most willing to work at the bottom of the range tend to be the ones with the least experience, and the moment they are being selected is the moment the form is hardest and least familiar.
The consequence lands on the homeowner, who did not choose the appraiser, is not the client, and generally never learns how the assignment was routed.
None of this is new. Fee compression through management companies has been a feature of lender work since well before I started. What the 3.6 transition has done is make the gap legible — when the workload roughly doubles and the offered fee does not move, the spread stops being a matter of opinion.
You pay for it, but the lender is the client. It is developed for the lender’s scope and intended use, and Appraiser Independence Requirements route your concerns back through the lender rather than to the appraiser.
My practice is private and non-lender. When someone engages me for an estate, a divorce, a tax protest or a filing, they are my client, they hold the report, and there is no third party between us adjusting the fee or the scope after the fact. The fee is quoted in writing before I start and it does not change with the value I reach.
That is not a moral position about anyone else’s business model. It is a description of a different one, and the difference is the reason private-client appraisal exists as a category at all.
It means the report was produced for the lender under the lender’s scope, by an appraiser you did not select and cannot speak to directly about the value, and that appraiser independence rules route any concern back through the lender.
You can also order your own. A private appraisal is a different assignment with you as the client — usable for a tax protest, a pricing decision, a family transfer, or your own information. It will not replace the lender’s appraisal for the loan, and I will say so plainly rather than let anyone assume otherwise.
Referring professional
“I’ve worked with Terrence at Clearfork Appraisals on several occasions over the last few years, and have referred him to numerous clients. He is able to explain the basis for his valuations in clear and understandable terms.”John Staab · Google review
An appraisal management company. It sits between the lender and the appraiser, administering the panel, distributing assignments, reviewing reports and handling delivery. The structure exists in part because appraiser independence rules after 2008 separated loan production staff from the appraiser, and management companies became the common way to maintain that separation.
Not all of it, and often not most of it. The appraisal fee on your closing disclosure is what you were charged. What the appraiser received is a separate number, set between the management company and the appraiser, and it is not disclosed to you.
Yes. Under 15 U.S.C. §1639e(i), lenders and their agents must compensate fee appraisers at a rate that is customary and reasonable for the market area, and the statute identifies the kind of objective evidence that establishes such rates. Enforcement is a separate question from what the statute requires.
More data collection, substantially more fields, new software from new providers, and the ordinary friction of everyone learning a new system at the same time. Appraisers have reported ten to sixteen hours on early 3.6 assignments. That figure should come down as the tools and the habits mature.
A single company deciding what it will pay its own contractors, and going elsewhere when the contractor says no, is ordinarily lawful negotiation, however unwelcome it is on the receiving end. Federal antitrust law under Sherman Act §1 reaches agreements between separate parties to restrain trade, not a firm acting alone. Coordination among competing companies about what they will pay would be a different matter entirely, and buyer-side agreements of that kind have been treated as serious violations — but that requires evidence of an agreement, and I have not seen any and am not alleging one. Separately, Regulation Z sets a compensation standard that applies whether or not anyone has broken an antitrust law, and conditions its safe harbour on the absence of anticompetitive conduct. Those are two different questions and they are worth keeping apart.
No. The phrase appears in this article because it appears in 12 CFR §1026.42(f)(2)(ii), which lists price fixing among the anticompetitive acts that cost a lender or its agent the presumption of compliance. That is the regulation describing a condition on a safe harbour. Whether any company has engaged in such conduct is a question for a regulator or a court with evidence in front of it, and I am not in that position. What I can do is set the regulation’s own factors — scope of work, time required — next to what has happened to scope and time, and leave the reader to it.
No. What an individual appraiser charges or accepts is that appraiser’s business decision, and it would be improper for me to suggest otherwise. I am describing what the statute requires of lenders and their agents, and what is being reported in the market.
You can hire your own, and you become the client when you do. It will not substitute for the lender’s appraisal on the loan — appraiser independence rules require the lender to engage its own. A private appraisal is useful for your own decisions: pricing, a protest, a family transfer, a divorce, an estate.
There is a defined process called a reconsideration of value, it routes through the lender rather than the appraiser, and it has rules and limits. I have written about how it works and what makes a strong request.
No. My practice is private and non-lender: estates, divorce, IRS filings, tax protests, partial interests, pre-listing and pre-purchase. When you engage me, you are the client and the fee is quoted in writing before I begin.
Written fee quote, typically within one business hour. Questions about anything in this article are free, whether or not they turn into an assignment.