Appraiser Rater: AMC Ratings by Appraisers

As suggested by readers, this space is designated for appraisers to comment on their experiences with AMCs that they have worked with. Whether it’s a major or private AMC, a good experience or bad, please share with your fellow appraisers. Include fee expectations, turn time expectations, unusual requests, flow of business, reporting requirements, ease of technology platform, payment and pressure issues or any other criteria. This is intended as a free exchange of information to help appraisers make informative decisions about the AMCs they work with. Please keep all comments constructive, factual and fair.

Please note that Working RE and OREP do not substantiate or verify any of the comments posted here.

602 Responses to Appraiser Rater: AMC Ratings by Appraisers

  1. Tony Grubb says:

    I have to say that accepting an order for $175 is shocking given how hard we’ve all worked to obtain our licenses/certifications. I remember just about a year ago I was getting paid $400 for a 1004 and now I’m doing them for $275 on average.

    We all know the horror stories of how AMC’s work and the fees they dangle in front of us like a worm on a hook. However, those of you accepting orders for a percentage of the fees we used to command are helping drive our fees down.

    As a father of 4 I understand the need to put food on the table. However, we’re supposed to be better than that. We’re supposed to tell THEM our fee and get paid for our work. Not the other way around.

    To hear an appraiser say $175 is ok is a disgrace to the appraisal profession. You should get out immediately because any appraiser proud of their career and hard work would never accept an assignment for that amount.

    We may not have a lobbying group or union organization, but we do have our Email and phones. Something must be and can be done to give us back control of our profession. Call or Email your Senator or member of Congress and tell them what the AMC’s are doing. Demand that lenders pay them and allow us to bill the lender directly. We can do this if we all want fair fees. But as long as appraisers accept orders for next to nothing it’ll just make the task that much harder. Stand your ground and we can make things happen.

  2. Mike Read says:

    Could you arrange to have the comments so the latest is at the top of the list, not at the bottom.

  3. Lori Davenport says:

    To Chris in FL, even though you didn’t mention me as a well-read professional, I’m OK, really, I am.
    I agree with you on forming a union. Not sure on standardizing fees – but it might actually be a good thing.
    Lets get the “National Independent Fee Appraisers Union” going. I’m on board in CT.

  4. Chris says:

    Certified Residential Appraiser, FL

    I have now read virtually every comment in this blog. I want to say that I appreciate the suggestions and comments put forth, particularly by several obviously experienced and well-read professionals, such as Chuck Miller, David in NC, Jeff Oliver and others. I am from a family of appraisers, mostly on the commercial side. My father thought I was crazy to want to be a residential appraiser–his comment to me was “they (meaning the lenders and government) step all over you…you have no lobby, no voice.” Sadly, he has been proved right.

    I love our line of work and I have watched our profession be hounded, beat up and railroaded in the past two years. We need to be unified, we need to act as one voice. As David from NC put it, “without an appraisal, there is (typically) no loan.” We have got to find a way, state by state, nationally, or both to unite as one. If we, as a PROFESSION, would take some initiative and stop viewing each other as competition and instead act on ALL our behalf, I think we could all work at a higher fee, make a better living and be our own advocates instead of taking whatever is shoved down our throats.

    I think standardizing fees and/or forming a union is an excellent start.

  5. Randall Haines says:

    I see all the comments that are satisfied with AMC’s, but no percentages on the values they do not get. AMC’s quit sending my Company assignments in late 2006, since I would not get there desired values. If you do not provide value for them, they will slowly phase you out for someone that will. Are these satisfied appraisers the same undertrained appraisers that got values for the AMC’s and lenders during the high inflationary period when they used unreliable data from some “rubber stamper”. If you do market research like your suppose to, and not plug in pretty numbers to meet desired ratios, you do not get rich in this business.

  6. Jim says:

    This appraiser has it RIGHT. The lack of independence has helped us down this path of inflated values. The only appraisers against HVCC are the ones whose next assignment depends on pleasing the mortgage brokers/lenders who can NEVER be pleased completely. Good editorial.

  7. Z says:

    Is there any professional office where a client can call/walk in and say “I need this and I will pay you X” and you have to take it? It’s called a flea market as far as I know….

    My favorite is the “Independent Valuation Protection Institute ” established by Cuomo for appraisers to turn to for complaints, assistance etc…It consists of 1 web page, no real info, no phone number for complaints which is supposed to be there, no email, no address….nothing.

    Lastly, I wonder why Mr Cuomo who is so intent appraiser independence from lenders turning around and allowing lenders to own the AMC’s? It is like having a farmer hire a wolf to watch his henhouse.

    My 2 cents….

  8. Dana Matonis says:

    As an appraiser with 26 years experience, if a client asked me what my fee was I would tell him. I’m under no obligation to shelter the income of the AMC.

    First I don’t work for AMC’s which is why I’m looking at early retirement.

    Second; by working for them for any fee you are helping them to stay in business.

    Lastly, Cuomo is the Attorney General of New York and soon will have to deal with the Department of Justice for overstepping his bounds. They will find him guilty of any number of violations of law not to mention his monetary gain from the “Code”, but because of his connections and wealth little will be done !!

    They are already touting him as the next Governor of New York because he has done such a great job ? WTF

  9. Richard Hardy says:

    I have been appraising in Hawaii for more than 15 years and elsewhere for longer. It is tragic to me that I haven’t yet seen any comments regarding the root of the ‘financial Crisis’. We (the people) had sufficient regulations in place to prevent what happened – Unfortunately it was NOT enforced. I am NOT the Bank that loaned my customers money to someone who walked in as a “Janitor” and stated he made $10,000/month and walked out with a loan far exceeding his ability. I am NOT the Underwriter who turned a blind eye to discrepancies in the loan package. I an NOT FNMA nor FHLMC who allowed continuing and exxceedingly higher and higher LTV’s to be acceptable. I am NOT the AMC who is owned by a bank, or an AMC who is owned by ‘that’ banks brother-in-law. I am NOT the appraiser who inflated the values. I AM however, an appraiser who spent the last 15+ years developing a good relationship with a variety of entities – some are AMC’s – some are Lender’s – some WERE Mortgage Brokers. But alas, Our government, in it’s infinite wisdom, has allowed an individual who nearly collapsed HUD to now ‘cramdown FNMA’s throat’ the “HAVOC” ,(read HVCC) which absolutlely will NOT solve the problem. Just as in the ’80′s, the appraisers were blamed for the collapse of the S & L Industry – We (Appraisers) have yet again risen to the ‘top’ and have single-handedly bankrupt the world . . .Unfortunately, the national appraising community is diverse, meaning we are 150,000 independant business people. I know AI is trying, along with others, bet we really are too fragmented – I wish I had an answer that would give all of us a common voice. But Wait . . .How about the Government? Don’t they work for us? Can’t we find someone in Congress who could see our plight? Or is it just going to be the continuing downward spiral . . .For me, I am a Flag Waving American – I believe in the ability of this country to wright itself. I am a hugh believer in that “One person standing alone is still a majority of one”. Damn the torpedos – full speed ahead


    I would be in favor of bypassing the AMCs by forming a trade assoication with direct contact with mortgage lenders. I no longer get orders from AMCs as I will not work for any less for someone who does not care about my appraisal license nor my livelihood verses the regular client pool I have in my local area. I have to laugh when I get a call from an AMC asking about price and will “get back to you”. 1-2 weeks have gone by and they call back and still insist on a 24 hour turnaround time- by this time I have picked up 2-4 new assignments that have become my new priority. ..

  11. Margie Gosser says:

    Hello, after 26 years in the business of having regular ethical clients, deciding how to handle pressure, deciding to be and act professional, I am pretty much leaving the profession. Pressure did not start with the real estate crisis. Who does not have day-to-day pressure in their business? Pressure to do OR not do the right thing? Lawyers, Politicians, Judges, Doctors, Government Lobbyist…come on!!! Now, the most unethical people in my day-to-day are the AMCs. AMCs want my professional services for a fee of $140, pressure me for a turn-time, don’t use me again if I don’t comply, & capture me with uneducated pressure & requests. I have heard there is a “appraiser black-list”…guess I am or shortly will be on it! I just can’t do it…I can not do ‘enough’ ethical services to PAY my monthly “running a business” expenses. How about this since “price fixing” is NOW where we are with AMCs. The Government form a Research Group inclusive of Appraiser’s from sections and sub-sections across the country to Provide a fair “Appraisal Service Form Fee Schedule” based upon time-Type of form that AMCs, Banks, Mortgage Personel would be mandated to use. It could be a “range” BUT fair to the appraiser in their Area- Scope. You could still discuss special circumstances but at least the fee would go up not down! This task would not take long or be complicated. Appraiser’s input would be paramount. As far as government cost…no more than the HVCC notification! AMCs have no regulation, not mandated to pay for services or abide by any rules. Government was at fault for not describing the clear use of AMCs in the beginning, AND AMCs owned by Banks are robbing appraisers of our FAIR WAGE. I believe the Government’s master plan is to get rid of appraiser’s…it must be because they have pretty much killed the profession. Who would want to go through all the education down time, pay all state fees, CE, E&O, software, advertising, and all else to make less than …being able to afford it?

  12. liz says:

    It has been very helpful reading this blog. When I first entered this world 12 years ago I was full of hope and excited about the appraisal profession. I feel I had great hands on training by my certified. I feel very confident about the quality of my appraisals and I am very thorough. I am horrified by the work that I review. So much so that it is not worth my time to review most of it as it takes too long to go over all the errors. It is a joke… I recently reviewed a report by an appraiser who has taken my workload by undercutting my fees and turntimes. He is a licensed appraiser and turns out terrible reports. He obviously did not receive adequate training. Back to the problem. I think there is a fundamental issue with this industry. I think it is poor practice to leave the training to individuals who view trainees as competition and use them for their gain until they can wobble out into battle and hopefully last long enough to establish themselves. Not all do, but a lot take advantage. What is going to happen to this industry if someone does not start turning out quality appraisers. It is left to us yet we don’t want to due to the liability and as soon as you train someone they leave and they are competing for the same work. I think bad appraisers give all of us a bad name and has added to the problem. I think low fees are not the core and or only issues here. I have a mortgage to make and you do what work you can each day. I don’t think not accepting an appraisal due to fee alone is going to change anything. There is not an organized front and at least i know that even though i occasionally take discounted orders I know they will get quality work from my office regardless of fee. I get irritated by the personal attacks by many in this blog saying accepting the lower fee is the problem! Because I accept a lower fee does not validate abuse nor does it condone poor appraisal practice by everyone involved.

    My dad started an AMC when all this talk of the HVCC first started. He had the idea that as an AMC developed by an appraiser would be fair and it would be an opportunity for appraisers to be compliant and keep some of the work they had established before hvcc hit. he only charges $50 per order so most work would still sit in the $300 range. He started contacting appraisers nationwide to get their workload processing through the AMC before the deadline so they could keep their business. It was pathetic! We were hung up on, laughed at, told we were trying to take their work, that HVCC was never going to happen and many appraisers knew nothing about HVCC two months before it happened. We have only ourselves to blame because we are clueless as to what is going on in this industry. We are cut throat and do not work together. I don’t know what the answer is but I do know that we are dropping like flies and I am so burned out I don’t care that I have lost most of my work due to my fees. I am still hopeful that this will still be a good business for me but I am looking for a back up as much of the braindamage may not be worth it anymore…

    side note: who is regulating the amc’s it seems it is left to each state to have certain guidelines. Why are we the only ones with heavy financial penalties not only from our board but civil as well!! Who is our advocate anyway.

    For what is it worth I have not had any issues with rels, my fees are 290 and i get more work when they are busy and random orders when it is slow. I have had a good experience with servicelink until recently now they want 200 and 225 per order. mda solutions i receive 260 to 300. After that, it is the random trickle when companies need something quick or a certified. I did not have a good experience with national and i am not inerested in their work. My dad has had decent work load with LSI at a discount of course. a little input from my experience hope that helps. Nice to vent to folks in the same boat.

  13. Guy in La says:


    I’m not sure if you were responding to my comment…if you were, let me say this. I don’t disagree with “anything” you say…I certainly understand the value of the service I and other appraisers like yourself perform – it’s the other guys (i.e. AMCs) who don’t! To them, this “is” a game – a numbers game playing one appraiser against the other – that’s my point.

    All I refer to in my previous comment is the very same “psychological marketing” tactics the marketing experts have been advocating for decades. And let’s face it – we are human beings – we have a brain, which immediately implies there is always some sort of “psychology” going on – especially when the other side (AMCs) is trying to use it on us. It’s human nature – and not a sin – let alone to raise question to my or any other appraiser’s professionalism. Personally, I don’t see the connection.

    My professionalism is there and apparent in every step of the process when I am performing an appraisal assignment. The “psychological marketing” tactics I use on AMCs have nothing to do with how I appraise – they’re just to achieve my desired fee. Not to mention those “professional” marketing experts (everybody pays money to hear lecture) would certainly approve.

  14. David says:

    Certified Residential Appraiser, NC:

    First of all, appraising is not a “game.” Why would an appraiser consider it as such? This is not a game! It’s a responsible profession that carries dire consequence if you falter in your representation of property data and value conclusions.

    The HVCC does not apply to appraisers, but to lenders. It has proliferated the use of AMCs and has promoted their purpose, whether intended or not. However, nothing has given more power to AMCs more so than the real estate appraiser. Appraisers simply do not understand the value of the “appraisal” in the overall lending process. They do not understand the Value Theory of Business and those who make decisions to accept the lower fees, ridiculous turn times, and allow the AMC to MANAGE their business are affecting the businesses of those who consider themselves to be true professionals who possess a sense of business and value contribution to the lending process.

    Try the following and see what results you get. Walk into a Doctors office for treatment. Tell the Doctor you are only going to pay $50 total for treatment, and this is not a co-pay, it’s a total of $50. You’ll immediately be told to “take a hike.” The Doctor knows that you will not get treatment for that price from another Doctor. You’ll simply do without treatment!

    This scenario may also be contributing to the low fees accepted from AMCs. An appraiser trains new appraisers and the trainees’ fee is $150. And suppose the fee, after experience is gained, reaches $175. The overall fee as an example is $350. The trainee, once licensed or certified, sees an opportunity to establish their own business. Keep in mind, it is very cost effective to register a company name, buy your own software and E&O, business equipment (which nearly everyone has anyway), and work out of your home. The newly certified appraiser sees this….”I can make $75 to $100 more for an assignment on my own versus working for my supervisor.” This is where the lack of business experience creates poor decision making and the decisions made by these inexperienced individuals becomes detrimental to other appraisers. Many appraisers have no clue as to what it cost to operate their businesses. I see this as a huge dilemma for those who do know.

    I recently made the following calculations regarding who is paid what in the loan process. It is based upon a loan of $175,000. The lender/investor is excluded as we all know their profits are astronomical. This scenario assumes mortgage brokers get 1.5%.

    Broker – $2,625, or ……….. 1.5%
    Realtor – $10,500, or …………6%
    Attorney – $600, or ………..3/10 of 1%
    Appraiser – $275, or ………..1/10 of 1%

    Let’s look at the contribution of the appraiser AND the appraisal in the lending process.

    I’ve applied my own scenario afterwards to show how appraising compares to the discussion.

    The following writings are from mathematicians and business scholars who have won Nobel prizes or have made contributions to the business and economic worlds. They include John Nash, John von Neumann, Adam Brandenburger, and Barry Nalebuff. The theory states, and by the way is proven to be true:

    The definition of added value is, “Added value equals total value created with you in the game, minus total value created without you in the game.” Consider the mortgage lending process as a “game.” A key concept of the “game” theory of business is added value. This theory states that if competition is left unfettered, no player will get more than his or her individual added value in a game. Thus, added value allows us to characterize who has power and who does not. It allows us to understand how the pie is created and how it is divided. Following is a way to think about creating value and capturing value. Understand, there is a dual purpose here. The first is where appraisers have failed, in my opinion.

    1. CREATING VALUE is an inherently COOPERATIVE process. To create value, people CANNOT ACT IN ISOLATION. They have to recognize their INTERDEPENDENCE. The IMPORTANCE OF THE PRODUCT, good, or service CREATES THE VALUE.

    2. Capturing value is inherently COMPETITIVE. Single entities wishing to capture value will make the individual determination as to the value of the product to be captured. Creating value that can be captured is the essence of business. However, one must realize, when more and more players contributing similar products enter the game, individual value can be diminished. This is competition.

    For example, what is the added value of the glass that makes up the screen in a laptop computer? Without strong and lightweight glass, there would be no laptop computers. So, the added value of the glass is the same as the added value of the laptop computers, which is enormous. The only problem is that there are several makers of computer glass. So for any one of them the right question is not what is the added value of glass, but what is the added value of their particular glass.

    Here the answer tends to be pennies, reflecting small manufacturing cost advantages. The computer makers would not miss any one manufacturer very much. Of course, that would be changed if one of them could develop a glass that was even slightly less likely to break than that of its’ rivals. A broken screen renders a laptop practically useless. Thus, the added value of a tougher glass would equal the whole pie multiplied by the reduction in the chance of breakage, which is likely to change the value of the particular glass to dollars per computer rather than pennies. What this illustrates is the gain from thinking about one’s added value over the value chain (the laptop computer) rather than one’s link in the chain (making glass).

    Now, let’s rephrase the above scenario to apply to the mortgage lending “game.”

    What is the added value of the appraisal that provides the property condition and value to a lender? Without an appraisal there would be no mortgage loan. So, the added value of the appraisal is the same as the added value of the mortgage loan, which is enormous. The only problem is that there are countless appraisers providing appraisal services. So for any one of them the right question is not what is the added value of the appraisal, but now becomes what is the added value of the individual appraiser.

    Here the answer tends to be pennies, reflecting competitive pricing for similar, undifferentiated services. The lenders or AMC’s/VMC’s would not miss any one appraiser very much. Of course, that would be changed if one of them could develop a means of completing quality, mistake-free reports in two hours rather than two days at lower fees. No appraisals renders the loan process worthless. Thus, the added value of a more reliable, faster, and cheaper appraisal would equal the whole pie multiplied by the improved service, which is likely to change the value of the particular appraiser to dollars per appraisal rather than pennies. What this illustrates is the gain from thinking about one’s added value over the value chain (the mortgage loan) rather than one’s link in the chain (the appraisal).

    This is a clear indication that the value within the mortgage lending process, or “game,” is the appraisal, not the appraiser. Lenders and AMC’s/VMC’s do not consider the value the individual appraiser provides to the process as they have injected their own guidelines that every appraiser must follow. Simply meet those guidelines and you have an acceptable appraisal, regardless of the quality of the data content. AMC’s/VMC’s primary goals are to find the cheapest and quickest, and those who can follow guidelines.

    For now, think of the “game” as a “pie” consisting of several “slices.” Each slice represents the entities involved in completing a mortgage lending transaction. They would most likely include: 1) the lenders; 2) the borrower; 3) the attorneys; 4) the AMCs/VMCs; and 5) the appraisal. One must ask, which slice of pie contributes the most value to the pie, and if that slice were removed, what then becomes the value of the pie? Remove the lender, no money, no loan. The pie becomes worthless. Remove the borrower, no loan. The pie becomes worthless. Remove the attorney. Deeds can still be recorded. Title searches can still be made. The pie may retain value, but the real effect is undetermined. Remove the AMC/VMC. Value is not affected. Remove the appraisal. The pie becomes worthless. However, replacing the appraisal slice with a multiple slices called “appraisers” diminishes the value of each appraiser slice of the pie. If one appraiser leaves the pie there are countless others to fill the void. The slice entitled appraisers has lost value until such circumstance arises where all appraisers leave the pie. At that point the pie is once again worthless.

    We are not an industry, we are a profession. And until we realize this and act as a profession rather than as individuals, we will never reach a plateau similar to that of Doctors, attorneys, or other highly skilled professions. I, for one, do not allow others to manage my daily business operations. I do not allow others to coerce, pressure, or intimidate me. I consider myself a professional and my business a profession, not an industry. I, like Doctors, provide a much needed service that has economic ramifications tthroughout the U.S. If that’s not responsibility I don’t know what is.

  15. Guy in La says:

    I share the frustrations of everyone here. I will offer a little advice that has worked for me to some extent with AMCs, but first I have to share something my father told me years ago – and I have to laugh at its present relevence. He once told me as I go through life…”son, if you ever have to be a whore, make sure you’re not a cheap one.” At a young age it didn’t make much sense to me back then, but I’m understanding he wisdom now.

    But for my advice at how I’ve kind of stuck it back at some AMCs. When they first contact me with an absurd low-ball fee, I give them a speech about how they are getting a “Rolls-Royce service for the price of a beat up Volkswagon” – I little fun on my part. I also ask them to take note of the quality of my work compared to other appraisers who work for the same peanuts.

    Then, after doing one or two jobs for them, I email them and ask them what they think of my work. I get a reply thanking me with a compliement on the quality of my work. I then email them back and say “okay, now that you recognize the quality of “my” service, here is my revised fee schedule of what I’m willing to work for. If I don’t hear back from you with any jobs, then I’ll understand your desire to use another appraiser.”

    What happens? Most of the AMCs I do this to will phone me. Naturally they’re not happy, they try to convince me to go back to my previously agreed fee. Now at this point, what does this tell you? It says they like my work and definitely want to continue using me – and of course I throw that in their face and let them know I know that’s why they’re calling me.

    I alway act magnanomous and say something like “oh, I perfectly understand if you wish to use a poorer quality appraiser at a lower fee, and I’m sure your lender/client will also understand.” They catch on quickly I’m not budging.

    The end result: they cave! Oh, there’s a few who won’t, but you would be surprise they will cave. Sure, the quantity of jobs much drop off – by a little – but I make that up by pulling this stunt with more AMCs to make up the difference.

    Trust me, this works. I have some of the biggest name AMCs paying me $300+. The trick here is you have to first “suck them in” by doing a couple of jobs at their fee, then pull the bait and switch. It’s about time we appraisers beat them at their own game. By no means am I trying to brag here, my intention is to help every appraiser in this country accomplish the same with these clowns as I have. I wish everyone great success!

  16. GFC says:

    Since May 1st when the appraisal industry was turned over to the AMC’s my 35 years of honest quality appraisal work by a staff of up to 24 appraisers in 3 locations is finished…….I quit! I just recently closed all offices and laid off all appraisers and trainees. The AMC’s still send a few low fee – fast turn around assignments which I accept, only to let them rot on the shelves never to be inspected or completed. Hope this helps the AMCs with their client relations. So long and good luck to all you good and honest appraisers.

  17. I was recently contacted by an AMC called Valuation Support Services. The approval packet they asked me to fill out included their fee schedule which I was required to agree to and sign. These were the lowest fee’s I have ever seen. Insultingly low. For example their 1004 URAR/Single Family fee is $200.00. In our area, the usual and customary fee is $310 at rock bottom to $350.00+. For a 2055 exterior they offer $145.00! Of course, I declined at their fees, but sent them a letter with my fee schedule attached, offering my services, should they decide to pay the customary fee’s. I am confident that NO competent appraiser would join their panal at their insultingly low fee’s. I only hope no one in my area sells out to them.

  18. Mike Goff says:

    I don’t work for unreasonable fees and unrealistic turn times. Look at VA fees and turn times, that’s the norm for residential assignments.

    I have over thirty five years in this profession and refuse to pimp myself, or my appraisers. Lenders, AMC’s, and form filling cut rate appraisers get what they deserve.

    When anyone wants the job done right, and wants to pay an reasonable fee with a realistic turn time, my office will accept the assignment. I get very few assignments from Lenders and/or AMC’s, what does that tell you.

    I turn in all “crap” work to the appropriate agencies, whether it is in review or if I find about it from another source. There is a lot of crap out there. I don’t review the appraiser, but the work product.

    It appears there is a lot of demand for review work. Get qualified to do this work, and clean up your profession. Get the “crappers” out of the business. If you want to accept low fees, I don’t have a problem with that, just do your job and govern yourself accordingly.

    Most AMC’s shun quality appraisers, and I am politically active in this regard. Get involved, it is your profession. Lots of States coming up with legislation on AMC’s, they need input from the quality appraisers.

    How do I live? My clients generally are attorneys, county and state government, and compliance review clients. Learn to testify or teach, it separates the wannabes from the real thing.

  19. Thanks Dana for the supporting comment.
    Going over some old paperwork from Realtor orientation back in 2001, I came across this page: “Appraisal vs CMA vs BPO”
    I am not going to copy all of the text, but there are some important things we were taught then, and I wonder if any of this is STILL the LAW in CT today. If so, lenders and RE agents are violating the law constantly by using BPO’s. Here are the items of note:
    “An appraisal is an analytical method of arriving at an opinion of value…developed using the guidelines of USPAP…requires an apppraisal license or certification…a CMA is not an appraisal but simply an analysis of properties that have sold or are on the market made in anticipation of obtaining a listing for sale…A licensed real estate broker may perform a CMA ONLY as part of listing a property…A BPO is similar to a CMA but is generally performed for a lender who has or intends to foreclose on a property. A licensed real estate broker or salesperson CANNOT perform a BPO except under the same conditions as a CMA…A real estate broker or salesperson MAY NOT CHARGE A FEE for either a CMA or a BPO without violation of the laws of the state of CT regarding licensing. ONLY A LICENSED OR CERTIFIED REAL ESTATE APPRAISER MAY RECEIVE A FEE FOR ESTIMATING THE MARKET VALUE OR MARKET PRICE OF REAL ESTATE”.
    I think many lenders and RE agents are in violation. First off because they know they are not doing it for the listing, but there are ways around that. But they ARE being paid a fee and that is in clear violation of what was taught to us in Realtor school. Unless of course this law has been done away with. Does anyone know if it has? What about other states?
    I know alot of our work has gone out to RE agents doing BPO’s but I had no idea that it might actually be illegal.

  20. Dana Matonis says:

    For those appraisers that have not read the information and findings provided by C. Butterfield et. al. with the Appraisers Union also know as the Real Estate Professionals Free Trade Coalition . Drop them a request at

    The information is well documented and it is a thourough and detailed explanation of the players, as well as the how and why, those in control are as commited to taking our income as much as we wish to keep it.

  21. Dana Matonis says:

    I’m going to support what was written by Lori Davenport earlier. AMC’s do not appear to be distributing work fairly, if they distribute it at all. I have been a appraiser since the early 80′s and over the years when approached by a AMC let them know under no uncertain terms what I thought of them and where they might direct their work.

    Fast forward to 2009 – and you guessed it – no work from AMC’s. Now I have been hearing rumors that later this year (August ?) FHA may start distributing their work through AMC’s.

    It would appear that those people that had a relationship with AMC’s in the past have faired well. I know of one local appraiser that is getting between 15 to 25 jobs a month and others that spend their day reading. Doesn’t sound like it’s being evenly distributed to me !

  22. Jeff Oliver says:

    So iwas reading that 54% of appraisers at least some of the time are asked to re-examine a report to potentially adjust the value to make the deal work….that is amazing to me because the AMC I am a part of has never done that once to my knowledge. The only thing we have ever sent back to the appraiser is requests for revision when there is an error. I am shocked that we as appraisers give in to this kind of pressure, knowing you could lose your license over something like that. Nearly 85% of all appraisals are being reviewed according to a friend who works higher up at a bank. So why run the risk. I get that we need the work and are therefore more willing to “bend” the rules to get it, but come on…if anyone loses their license they lose 5, 10, 20 years worth of income!!!
    We just kicked one appraiser off our list because they could not be bothered to update our company of a problem getting into the house and therefore the appraisal report was late…we gave this person more than 7 days to complete it. Come on people, you can complain all you want but you also gotta be somewhat flexible with companies who have clients to keep happy also. Some appraisers need to get over the arrogant appraiser attitude and start doing a good job or start losing business!!!

  23. I have had it with government intervention in the name of helping the appraisers not circum to the pressures from Mortgage lenders. I have run my own business for 7 years. I picked and chose who I worked with in order to keep my license clean. So I could trust who I was working with and they, in turn, could trust me to keep them out of trouble as well. Since the HVCC, I have lost every one of my clients! What happened to Free enterprise?? I believe HCVV is Unconstitutional ! I am being helped right out of the business. What other business in the US is told they can no longer work with, talk to have a relationship with their current clients? I don’t need a mediator to run my business, especailly one that seemingly has no rules of engagement! I am on 20 lists and received 5 appraisals last month with reduced fees!!! Guess I have to get on 100. So why did I go ahead and become certified? I am hoping that FHA never becomes HVCC and I might still have a bit of independence! Take a look at the statistics for the number of appraisers for your state listed on the ASC website. You can get a complete listing of all the appraisers that have been licensed in your state. Of the 12,191 appraisers in GA there are only 4600 +/- who are still active. (Over 600 went out of business last year!) Of those 4600 +/-, there are only 2700 +/- who hold the CR or CG designation! Guess there should be plenty of FHA appraisals if I can survive until October! Let’s tell the oil companies that they need to pay a third party to pass their paperwork through, see how well it works in other professions! No, actually they would just raise gas prices. Shame we don’t have that same opportunity to control our fees!!

  24. I dont think there is any other job where no longer can you put your name out there, do a great job and expect your good product and service to be good advertising for you. In fact, there is no point to advertise at all. We have no freedom to run our business. We are at the mercy of being picked out of a hat.
    I think the issue here is bigger and worse than we can imagine. We have lost all control and have no freedom to be INDEPENDENT FEE APPRAISERS, as the name suggests.
    All the work and effort….It is extremely hard to get an appraisers license in this state (CT) with all the classes, finding a supervisory appraiser and actually getting enough assignments for your hours needed (not to mention your split will be ridiculously small now) and now you have to have a college degree and the state exam is very difficult with a very low pass rate.
    Who is going to be stupid enough to enter this field now?
    But hey, who needs appraisers now anyway? All you gotta do is call a RE agent and get a BPO, because they seem to be just as good as an appraisal these days.

  25. John A. Humm says:

    So, now we are forced to accept fees which are from the 1970′s which are much less than escrow, title and of course, the mgmt. company’s fees. The mantra now is: “Make the appraiser pay for the AMC fee! They are the ones to blame. The lenders can’t pay for THAT… ” Seems fair. On top of that, the borrower is paying more for the appraisals than before this insanity and they are mad at the appraiser for that. Our expenses are from the 21st. century but they want us to work for 20th. century wages. Its an outrage but that’s what you get when you get the government involved in things as they usually make a mess of everything they touch, unless of course its Congress’s salaries. Where was our industry leaders when this insanity was being put together? Probably making more regulations and setting us up for more classes to take. Why should we as an industry accept anything less than full fees and reasonable turn-times. We need fair compensation. We’ve worked hard to get those fees up over the years and to be told to shut up and sit down is wrong. I too have found that the majority of the orders in my area have been going to the big shops. I can’t even get into these AMC sites fast enough to grab an order. I even got a Blackberry to speed up the process only to learn that Blackberrys are on a time delay as is Outlook and Outlook Express. So you’re dead if you try and use these. I questioned my cable provider as I thought someone had to have some kind of an auto-responder but no, the cable company doesn’t offer that type of feature. So the big guys have an in and the rest of us are told: You can’t talk to your old clients, you can’t engage new clients either and you can’t get in to get any orders. Unfortunately, the cure is worse than the disease ever was and its likely to ruin a good many of us honest appraisers before something is done to correct the mess this Obamaination of desolation has caused.

  26. By the way, I have signed up for a few, 3 or 4 AMC’s and still have not gotten ANY work from any of them. So how is that possible if they are supposed to rotate appraisers and use them autonomously?
    Is it because now instead of the brokers picking up the phone and calling their favorite appraiser, its now the AMC’s that keep using their favorite appraisers based on the lowest fees and willingness to submit to their pressure?
    What the hell is the difference other than another layer of greedy hands skimming off our pay?
    Only difference is, now I have no work in that arena. Thank god for FHA.

  27. 30+ yrs & considering leaving the profession says:

    I just reviewed my first application to work with a large AMC. Am I the only one that has a problem signing their broad and invasive “Authorization For A Background Investigation.”

    I understand an AMC’s need for a credit report, a state disciplinary check, a criminal background check, a verification of my education, verification of my experience, and speaking with my past employers or clients but I do NOT understand authorizing an AMC to speak to “any other persons,” or investigate my “mode of living” (what does that mean?), or obtain records that are unamed in the request (they use the term: but is not limited to), or have copies of my medical records. Yes….MY MEDICAL RECORDS.

    I am an excellent appraiser. I have 30 plus years of appraisal experience. I have no criminal record, no prior or pending disciplinary actions. I have extensive appraisal education. A couple of designations. I am a participating member of my community and volunteer. I have no existing medical problems and take no medication (I would be okay with a drug test), and I know of no one that would state a negative thing about me (not even my ex) but feel they ask too much of an Independent Contractor.

    There is no disclaimer that this information will not be sold, how safe it will be, and the only expiration of this authority is when your relationship with the AMC ends. In fact, in goes on to states that you can be investigated “at any time” AND unless you live in 1 of only 5+/- states that require them to make the investigation available to you, you will never know what is in your file or how many times you are investigated.

    I have had two attorneys review this very broad and invasive investigation request. Both advised me not to sign. Please explain to me why you did? I am not saying you are wrong…just explain to me why. Do you feel safe that it will not be misused or somehow not go into some database?

    I guess being brought up in the 70′s has made me paranoid about “Big Brother” watching our every move but truly I have nothing to hide. It just feels wrong. It feels like I am slowly giving up some of my precious US citizen’s rights.

  28. ken says:

    I am yet to see one AMC that has decent fees. At least five of them contact my office on a regular basis looking for bids. The fees are never in line with the industry and they want the appraisal back in two days. If you had a decent business with mortgage bankers and brokers the AMC’s just destroyed it. With all the new requirements on residential appraisals it is taking a lot longer to complete each assignment. I am working fifteen hours more each week and lucky to make two thirds the money in past years. Unfortunately we do not have a real national organization that would have paid someone to lobby against the management companies. This business will never be what it was in the past. We are better off finding a side way to supplement our incomes versus hoping for positive changes. Until we have a true voice in the industry we will always be thought of last.

  29. Jeff Oliver says:

    I am guessing Stacker works in an area where that kind of fee will suffice and pay his/her bills. Here in Los Angeles makes $150/appraisal wont even pay my mortgage. Things are way over-priced here, yes I know, but the fact of the matter is if you spend on average 4-6 hours doing an appraisal then you are only being paif $30/hour for your time…that is ridiculous for a professional these days. I see other people going into careers where they make $30-50/hr with no experience or anythign required…I love appraising but we have got to come up with a united voice. I agree completely with Lori Davenport that we are like spoiled kids and I dont think any of us would be complaining if the fees dropped slightly, but getting cut in half is absurd!!!

  30. Stacker says:

    I have been contacted by one AMC and their offer for a fee has been more than what I normally charge. Told my FHA lender how much more they will charge and he told me they may reconsider using AMC for their FHA.
    I don’t see the big deal with AMC. When you do work for an appraisal company like I have been doing for 15 years with a split fee of 50-55% then what the AMC pays seems in line. But now that company has to receive orders from AMC and if their fees are lower than going thru the lender that means my percentage will be even lower. Instead of around $150-180 my cut will drop lower. So the $145 which is mentioned from someone else may be in line. THat means the appraisal fee must be about $290 which is only about $10 less than the normal fee for the URAR. I guess we gotta be glad for what ever it is in this rough economic times. Just be glad we got work even though it isn’t much and we gotta supplement it with something else for now. We have to hope the economy turns around and we all get business again. If not, its not worth renewing license.

  31. Interesting….I’d like to see where that goes.

  32. Chuck Miller says:

    The fee structure would be the minimum with negotiable increases for complexity. We can take on the bully, one voice you’ll hardly hear 10,000 voices you can’t miss. I am writing a draft to send to the ASB and others to see what kind of feed back I get

  33. bajou says:

    After nearly 20 years of appraising, I’m making better money in accounting & bookeeping services, normal work week, far less liability.

    AMCs are the appraiser’s pimp.

  34. Just came across this…

    We should all sign it, and forward it to others. I’m not sure if it will do any good, but it cant hurt. There are 9,598 signatures as of this post.

  35. At first thought, a fee structure sounds terrible and something I didn’t think I would ever consider, but may be worthy of a ponder. Maybe (big maybe) its not such a bad idea, as long as there is a way for us to make changes without too much bureaucratic ado.
    But there are too many “what ifs”.
    It may work for “standard” appraisals, but what about difficult ones? I can see that it would help to keep AMC’s from access to our pockets, but how would it help otherwise?
    Maybe we should all just be subcontractors for the government.
    In real estate, the market governs the commission. Appraisers cannot work for commission but if we let the market govern our pay, then we get what we got now. There are too many appraisers willing to work for half of what we are used to, which means we all have to lower our rates (or the quality) to stay competitive. In real estate, if half the agencies lowered their commission rates, the rest would have to follow to stay in the game.
    Part of the desire for us to become independent fee appraisers is because we want to work for ourselves, we don’t want to answer to others, we want to set our schedules, our fees and we trust our skills and our competency. We don’t want others telling us what to do. Those are strong qualities, but we also don’t like to stand up for ourselves. We are alike a bunch of spoiled children, we want to play by our own rules, but we still want mommy to fix things when the big bully tries to take over…problem is, in this game there is still the whiny child and the big bully, but no mommy.
    Do we need one? Or can we take this bully on, on our own? It remains to be seen. I’m not sure I want to play this game anymore. Life is too short.
    I’m not opposed to finding other ways to pay the bills, being multifaceted is a good strategy in this economy. I never liked relying on one source of income.

  36. Chuck Miller says:

    Ms. Davenport, that is exactly my point “All the ASB and the Appraisal Foundation do for us is give us more guidelines to follow.” they govern what we do and how we do it. Get them to mandate a fee structure we can live with.

  37. Chuck Miller says: “We as appraisers get the least amount of money for any real estate related transaction, a mandatory service with a hefty chunk of accountability attached. Doesn’t seem quite right does it.”
    And that is the reason we are in this predicament. We are on the lowest rung. Money speaks. Are we just patsies in the big game?
    I am also a Realtor and I have to say, for all the dues I send to NAR (National Association of Relators) and the local boards as well, in the end, its worth it. They speak for us, watch out for us and lobby for our best interest. Its nice to have a voice in Washington. The lending institution has it….Appraisers dont.
    But NAR is on our side. They have fought against the HVCC. They have done more for appraisers than any appraiser association or governing body. All the ASB and the Appraisal Foundation do for us is give us more guidelines to follow.

  38. mister d says:

    I hear everyones complaints and I myself am quite upset about the HVCC as everyone is well aware that it is a truly absurd joke that will accomplish nothing it claims to correct. Following are a couple things I suggest appraisers due to combat this fraud.

    First: Create your own AMC. It is quite easy to file corporate papers and the costs are minimal. You can then accept orders from your own AMC. Be sure to follow all the rules within the HVCC. It is simpy a matter of paperwork.

    Second: Do not perform work for any other AMC’s period. I personally have only found one out of the 30 that I looked into that I could work with that didnt violate the HVCC rules they claim to adhere to. Over 25% stated they performed pre-comps on their web sites. Not to mention that most of the contracts they offer a retard would know not to sign.

    I personally have decided to stay away from mortgae appraisals for the time being as the process to eliminate quality appraisers from the industry is beyond obvious. Jp morgan’s act of filing 2000 complaints with numerous state boards says everything. Most people do not know why they did this and the answer is quite simple. They filed these complaints to remove unwanted quality appraisers from their AMC’s roster. Shortly after filing these complaints they required all of the appraiser on their AMC’s approved list to reapply due to the new HVCC guidelines. One of the first questions on the list was one about compliants filed against you or your cmpany and of course if you have a complaint they would deny you access to their list. Removal of quality appraisers accomplished.

    The most amazing thing about the HVCC is that the author MR. Cuomo not only was one of the key players in the demise of fannie and freddie as he destroyed all quality control measures in place while he was the Sec. of HUD. He also was on the board of an AMC named AMCO just prior to becoming Attorney General. Amco was bought out by dwellworks then renamed Valuation Services. This is an obvious attempt to disconnect ties to Mr. Cuomo. He actually had an advisory title. He was their advisor on government regualtions.

    If you want to understand Mr. Cuomo and his objectives I highly suggest you search “cuomo hud and fraud” you will need sevearl days to absorb all the facts.

    A few more hilarious facts about the HVCC, Fannie and Freddie.

    1: The same week the HVCC went into affect fannie and freddie anounced that they will now offer a streamlined refi with no appraisal required. They are claiming concern for making quality ledning decisions while performing loans without appraisals in a time when most markets are decling. Obviously their only interest is protecting the banks principal inetrest. In my opinion they are simply kicking the can down the road.

    2: Just yesterday Wells refused to accept an appraisal performed by my AMC and required a review performed by their AMC resdirect. I cant wait to see it as i had 4 sales, within 6 months, within 200 square feet, from the same subdivision. They actually made me provide a 5 comp that bracketed the square footage. Nowhere in the HVCC does it state that the lender can require that you use the AMC that they require. It simply states that an AMC must serve as a firewall. Steering by lenders to utilize service providers they require is in violation of FIRREA, RESPA and Title XI. As a matter of fact it is the fundamental foudation for RESPA. Keep up the good fight and good luck to all of us who were foolish enough to choose this profession.

  39. Jeff Oliver says:

    Chuck Miller…you are absolutely correct. I wish, for my own benefit, that there was standardized pricing!!! Then the quality would be the only thing companies would have to pick their appraisal company by. Also with standardized pricing the lending companies would realize that we are united at least on one small part which would pressure the goverment types to take heed and pay attention when we say there are horrible appraisers out there who need to be dealt with. As it stands right now policing ourselves does no good when they won’t punish these people!!! I think Mr. Miller is onto something. We should begin to communicate this with gov’t and get them to pass some sort of legislation as to minimum fees or some sort of regulated pricing!!!

  40. Chuck Miller says:

    I too agree in part with Bernard and Mr. Oliver that as a whole the appraiser has allowed the industry to dictate and lessen the role of the appraiser. Also I agree the those who commit fraud or grevious errors in judgement should be held accountable and liable for punitive measures. Unions more than likely are logistically impossible under the current structure. I also imagine that every other unionized business sector said those exact same words. The desired end result we all should agree on is business, the right to a reasonable fee for service provided. We as apprasiers get the least amount of money for any real estate related transaction, a mandatory service with a hefty chunk of accountability attached. Doesn’t seem quite right does it. No matter how you do it, one service, bundled services or part of a larger management service the appraiser gets squat. Yes, there are unscrupulous, untrained and sub standard (insert your profession here). Its not just appraisers, each of you appraisers, brokers, reviewers etc. have contributed to the mess and each has applied pressure in some form to make a report conform to a preconception of value wished for etc. Before anybody gets on the higher horse and says not me I will say B.S. It is about cultivation and retention of clientele in short business. I know it and you know it. Granted some go further than others but absolutley no one is innocent. At this point the implementation of HVCC and its directives towards AMC’s is unavoidable. Nobody, myself included has come up with a way to retain what little percentage of the pie we get. For licensed proffesionals that are required to know the various values of a dollar how can we be so stupid to think that rising cost and shrinking fees would be ok, because we are told it will be better? Unified presence, pressure and voice to the Governing body, ASB, USPAP those 2 bodies that govern all appraisal writing need to be persuaded that an implementation of legislation promoting fairness of fees to be paid to the appraiser be consistent with the economic equivilent of the cost of doing and maintaining an appraisal business. Change the laws…Everybody else can tack on what they like over and above our fee. That I beleive is the solution, we get a set fee, starting at $350 with incremental negotiable steps of $100 for complexity. 2-4 family start at 450 with the same negotiations. Pass or fail an order is accompanied by a remitted fee. If I have to be the horse that pulls the cart I want carrots and apples too.

  41. Jeff Oliver says:

    I completely agree with Bernard…we have done this to ourselves. The sad part is that many people like to complain about things and very few come up with REAL solutions. A union is probably not gonna happen just by the sheer nature of the industry and the fact that the larger money lies in the hands of the AMC’s, which are nothing more than puppets of the big banks. That is why my company has banded together to do concerted marketing, ordering, technology, etc and tried to minimize the admin fees that are necessary to run any good company.
    I truly believe and have been saying this for a while now that we ought to start getting angry with the various state governing boards. Here in Calif, they act like their hands are tied. If a person commits fraud, or any other illegal act, they ought to lose license, be fined and jailed!!! Period. Stop trying to play nice guy…the so called watchdogs have ruined the industry by allowing puppy mills, and not prosecuting people when they are caught. Start weeding out the bad appraisers who defile this great career. Think about it, if the bottom 1/3 of bad appraisers were removed from the pool, this would not be an issue because there would be more work for you and me…

  42. Chuck Miller says:

    Sigh… yes we are a wierd bunch, secret squirrel and morocco mole types, put us all in a room and appraisal stories overcome nascar and women, believe it, actually seen it from the inside. But never the less it is the nature of the business we have all worked so hard to build by that same secrecy. The all important client list has been laid waste to by the stroke of the pen. I’ve read 99 % of these remarks and replies from both appraisers and employees of various AMC’s and other institutions. It is interesting to see the lack of understanding by those who question why a business man or woman would be upset at having their workload increased and fees cut at the same time. My self I still am of the belief that we should be united, our fees be standardized at a reasonable figure that would allow us to succeed rather than merely survive eking out a meager existence. If you look beyond the initial rant each of us have contributed something here. Union, Standard fee, Rotating selection pool and so on. If you put these all together it really might work. I’m sure those on the other side of the fence who stand to lose a little of thier new income might balk but hey welcome to our world. The real question is how do we do it, sucessfully organize to be a unified force and retain some semblance of our independence. any suggestions? I have one lets get the brokers and loan originators who get 6 to 25k per sucessful loan to cut thier fees and meet our full fee right? I mean if it is going to be a symbiotic relationship why would you cut off your nose to spite your face

  43. Bernard... says:

    The AMC’s are good for appraisals who are afraid to grow a business & rather be order takers or told how to run thier business. Appraisers you are small business owners act like it. Why in a million years would you give up your control to an AMC’s. Who the F*** are they to control YOUR salary. What are they doing except answering an e-mail or phone call from the Lender. Real talent, I just took an appraisal order now I will take half your pay & you will say AMC’s there not that bad to work for. WOW, Now, at 40 years old I understand how Hitler came in to power. He didn’t take the power. The people just let him have it.

  44. Thanks for the dead on observation Lori. We all deserve what we get because we all cowered and allowed our so called profession to be hijacked. Someone else said they won’t prostitue themselves – well put. As of yesterday, I have lost 90% of my customers – which really hurts because my business more than tripled after the 1004MC form from hell came into the picture. Oh well – have at it boys and girls – fight over the scraps. I won’t miss working 7 days a week, day and night. I might get a real job and have a real life – yeah, a weekend is sounding better all the time… thanks for the experience and knowledge. I hear the train whistle now – time to leave. Good luck and Good riddance.

  45. Lori Davenport says:

    Many of you are saying you work for a decent AMC, but wont give up the name.
    Secrecy, afraid of sharing work. Appraisers are a weird bunch. Maybe this is why we have let the lenders, AMC’s, brokers and lawmakers make our decisions for us… because we are afraid. Are we a bunch of greedy, secretive, wimps? Appraisers like to complain and we dont play well with others. By nature we cant band together. We cant even share the name sof the good AMC’s. Come on people, maybe if we helped each other out from the beginning, we would not be in this current situation.
    We let this happen. We need some spinal cords and we need to demand respect.
    I wont work for beans. And yes, I have less work. But I have a conscious and I wont be used. If we stand up to our belief that our work is worth more, instead of submitting, we might be heard. Im on strike. Wont work without respect.

  46. Lee Bell says:

    I had the same question as Elana.

    If I was a trainee I’d be glad to give up half the fee for mentoring, but my trainee days are long over.

  47. Elana Riedel says:

    So Jeff Oliver, what is the name of your AMC and are you adding to your experienced appraiser panel?

  48. Jeff Oliver says:

    I agree with Southern California Appraisers in that the companies need to simply charge a processing fee to the banks. Our AMC is simply charging a slightly higher fee to the client, then only subtracting a minimal amount so the appraiser is still in most cases getting between $250 to $325 per job. This may be less than what we are all use to getting from $350 to $450 per job, but granted the appraiser does not have to do any marketing or anything to get the job except do good work. I think one of the keys to this whole problem is appraisers deciding not to give into the pressures of doing shotty work even when the fees are lower. As a reviewer for many companies I am seeing really awful reports coming across and it seems to be based on the fees being paid to the appraiser.

  49. Susan McMillan says:

    Chuck Miller and Jeff Oliver suggest interesting possibilities. Form our own union and/or AMC. Let’s bite the bullett and become “co-dependant fee appraisers”

  50. noname says:

    STEVE SOUZA // Apr 29, 2009 at 5:54 pm

    I have been approached and work for 3 fairly good AMC’S that pay “reasonable fees” even though they are less than my normal fees I’ve been charging for the past 4 years. I had a Borrower call me about a week ago and wanted to know what his lender was paying me because they were charging him $750.00 for an appraisal and he felt he was getting ripped off for that fee by me. None the less, per privacy I told him I could not discuss that issue with him. He said he knew where I lived and I asked him if he was threatening me. He said take it for what is worth. I filed a police report. Bottom line, the Borrower is thinking we are the one’s getting these fees. Crap, my fee was in the $200’s range. No wonder we are hated huh? Lenders and AMC’S are sticking it to us good and we need to stand up “together” and stop this. I for one will be out of business in 2 years if this continues and can’t say I’ll miss it. Tired of working for minimum wage.


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