Appraisal Fee - Markup or Kickback? - Part 1

Appraiser Question: "I received an order from an Appraisal Management Company (AMC) that requested I bill the client $75 more than my standard fee and return $75 to them. I've never heard of this before, but I haven't worked with many management companies. Is this common?" "Do I need to make a statement in the appraisal report that I have paid $75 to the AMC?" "Are there any other USPAP or legal concerns that I should consider to cover myself?" Some Appraiser Reponses: Appraiser: "I have a company that I do work for and they charge $50 per appraisal. I have no problem with this, I charge the customer my fee, provide an invoice for the entire fee and pay the company for each appraisal that they assign to me. Am I doing something that is illegal? Would this be considered a kickback?" Appraiser: "At least two of the AMCs I work with inflate the quoted fees to the borrower and take their piece back when collected. It happens to be $50 in each case. I have no objection as long as I collect the fee before I pay them their end. " Appraiser: "In my opinion the $50 is for a service performed by the entity acting as the AMC and is not violating RESPA. They have to do some administrative work at the least and make a panel selection to the referred appraiser." That was just a few of the responses to a debate on how to handle additional fee requests from lenders, brokers, and appraisal management companies. I'd welcome YOUR thoughts on this topic before I blog MY opinions later today. Just add your comments by clicking on the "Comments" link below.