1. Welcome to AppraisersForum.com, the premiere online  community for the discussion of real estate appraisal. Register a free account to be able to post and unlock additional forums and features.

C&R: October 20th = April 1st

Discussion in 'General Appraisal Discussion' started by HF Mudd, Oct 18, 2010.

Thread Status:
Not open for further replies.
  1. HF Mudd

    HF Mudd Senior Member

    28
    Jul 31, 2005
    Professional Status:
    Certified Residential Appraiser
    State:
    New York
  2. Riick

    Riick Elite Member

    40
    Aug 14, 2007
    Professional Status:
    Certified Residential Appraiser
    State:
    Delaware
    Read it and.....
    Well, here it is attached

    :new_2gunsfiring_v1:
    .
     
    Last edited: Jan 4, 2011
  3. Denis DeSaix

    Denis DeSaix Elite Member

    232
    May 16, 2005
    Professional Status:
    Certified General Appraiser
    State:
    California
    I think this is the significant section everyone will want to read (p. 9):

    As I read this, this is what I understand:
    An AMC (or other entity) is presumed to pay R&C fees if
    One: (a) it is based on recent fees within the geographic area and considers assignment and complexity, and (b) there is no evidence of collusion to hold fees to a certain price, or
    Two: The AMC/entity can adopt VA or other independent fee survey schedules.

    What I do not interpret this to mean is that an AMC must adopt VA or other published schedules.
    What is implied (to me) is that the R&C rate is based on what the market will bear and is negotiated and accepted by the appraiser.

    Does anyone have a different interpretation?
     
  4. kevco

    kevco Senior Member

    43
    Feb 10, 2009
    Professional Status:
    Licensed Appraiser
    State:
    California
    Nope! It looks like the banks and their lobbyists got what they wanted. Did you ever think it would be any different?
     
  5. Winston Wolf

    Winston Wolf Member

    0
    Jul 4, 2009
    Professional Status:
    Certified Residential Appraiser
    State:
    Maryland
    Let me fix it for you...C&R: October 20th = $185.00 because those who have the gold make the rules.

    You all need to get out of mortgage appraising.
     
  6. kevco

    kevco Senior Member

    43
    Feb 10, 2009
    Professional Status:
    Licensed Appraiser
    State:
    California
    Like I have been saying on this forum for months and months but most wouldn't listen. Fees are going down not up. Washington was just telling Marion what she wanted to hear and did whatever they wanted anyway.
     
  7. Denis DeSaix

    Denis DeSaix Elite Member

    232
    May 16, 2005
    Professional Status:
    Certified General Appraiser
    State:
    California
    I just spoke to a very knowledgeable person in the industry, and he/she has pretty good take:

    She/he reads the announcement and thinks this is good news (or, at least, not all bad news) for appraisers.
    The AMCs are not "off the hook" as far as R&C goes. And, the banks (who are ultimately responsible) can choose to tell the AMCs,
    "Look, we don't want any regulatory risk, pay these guys VA fees and be done with it".
    This person has some other good insights, which lead me to believe that the ruling of non-adoption may not be as terrible a thing as it first sounds.

    What I do think is also good is this: Up to this point, appraisers have been pushing-back on fees. And, per many forumites, fees have been going up. So, the push-back has worked. No need to stop on that front (which is a market-driven solution).
     
  8. Highlander416

    Highlander416 Member

    11
    Feb 16, 2003
    Professional Status:
    Certified Residential Appraiser
    State:
    Massachusetts
    I think that I do see it a little differently.

    The govt is not going to simply impose, for example, the VA fee schedule on all lenders nationwide. I see the second part that mentions the VA fees as more of a "safe harbor" provision. For example, if a lender decides to use the VA fee schedule, they are safe from dealing with the fee issue at that point. In other words, if you don't want to go thru the trouble of arguing over what a C&R fee is, you can just use the VA fees and be done with it.

    I don't think the AMC's will be able to argue they just ignored the C&R fee section about using surveys that do not include AMC fees, by simply saying they did a survey, which included just looking at their own fee schedule and agreeing with it, and just doing business as usual.
     
  9. Flygirl 152

    Flygirl 152 Senior Member

    0
    May 3, 2006
    Professional Status:
    Certified Residential Appraiser
    State:
    California
    Denis, when I first read this section, I thought it meant that during the interim period, it is assumed that appraisers are being paid C&R until the April 11th deadline. Further determination would then be made after public comment and fee studies.

    Your interpretation has changed my mind though, and I am now leaning away from my initial thoughts.
     
  10. Highlander416

    Highlander416 Member

    11
    Feb 16, 2003
    Professional Status:
    Certified Residential Appraiser
    State:
    Massachusetts
    In addition, this sets up a situation where appraisers can really bombard their Congressman and Senate members. A letter with the VA fee survey and AMC fee schedule attached showing fees $200 apart. Before now, we could call and claim we thought VA represented the C&R fee, but it was a matter of opinion. Now, we have a law that clearly states the VA Fee IS considered a standard for C&R fees to the extent it was even referenced in the law itself.
     
Thread Status:
Not open for further replies.

Share This Page